The Department of Finance today released for public comment a package of draft legislative proposals relating to a number of technical changes to the Income Tax Act and the Income Tax Regulations.
Many of these proposals respond to issues brought to the attention of the Department by taxpayers and their representatives. This release is part of an ongoing effort to ensure that tax legislation is clear and reflects the underlying policy intent.
The proposals include technical changes relating to:
- the computation of adjusted taxable income for the purposes of the alternative minimum tax;
- the prohibited investment and advantage rules for registered plans, including the changes set out in the letter dated June 12, 2012 to the Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants;
- a simplified method for determining the Canadian-source income of non-resident pilots employed by Canadian airlines, as was suggested by the Tax Court of Canada in Price v. The Queen, 2011 TCC 449; and
- a number of amendments to sections 55 and 88 of the Income Tax Act related to comfort letters issued to taxpayers by the Department of Finance, along with a change to section 88 to ensure that a parent corporation cannot benefit from an inappropriate step-up in cost base on the winding-up of a subsidiary corporation.
Full explanatory notes are included with the draft legislation. References to “Announcement Date” in the draft legislation and explanatory notes refer to today’s date.
Interested parties are invited to provide comments on the draft legislation by February 19, 2013 to:
Tax Policy Branch
Department of Finance
140 O’Connor Street
Ottawa, Ontario
K1A 0G5
or by email: consultationTA2012-MT@fin.gc.ca
Kathleen Perchaluk
Press Secretary
Office of the Minister of Finance
613-996-7861
Jack Aubry
Media Relations
Department of Finance
613-996-8080
