Budget 2014 projects a deficit of $16.6B for the current year, $2.9B for 2015 and a surplus of $6.4B for fiscal 2016. Contrary to expectations, the budget document is a very detailed and lengthy "action plan" focusing on job creation, innovation, and infrastructure projects in various regions of Canada. While tax measures are not center stage, there are still a significant number of tax measures designed to close perceived tax loopholes, including measures to address immigration trusts, tax rates on testamentary trusts, business and rental income of trusts and partnerships, tax transparency, treaty shopping and thin capitalization, as well as a proposed discussion paper on charities and not-for-profit organizations. There are also measures to address tax fairness, as well as some benefits for our amateur athletes (announced, appropriately, during the Olympic Games).

The following highlights the main tax measures announced in Budget 2014.

A. BUSINESS TAX MEASURES

Reform of Eligible Capital Property Rules

The Income Tax Act (Canada) (the Act)1 has long contained a specific and complex set of rules governing the treatment of expenditures that are capital in nature but are incurred for the purpose of producing income from a business. Under general principles, these expenditures are not ordinarily deductible in computing the income of a business. However, under the eligible capital property rules, 75% of these eligible capital expenditures are generally included in a cumulative eligible capital (CEC) tax pool and are deductible at a 7% declining balance. These expenditures are often on intangibles such as goodwill and certain patents.

Conversely, a taxpayer may sell certain intangible capital properties and have an eligible capital receipt. The eligible capital property rules generally require that 75% of such receipts be applied to reduce the cumulative eligible capital pool, followed by a recapture of CEC previously deducted. Once all the deductions have been recaptured, 50% of any remaining amount is included as income from a business, which mirrors the rate applicable to capital gains.

Budget 2014 announces a consultation to repeal the existing eligible capital property rules. In their place, a new capital cost allowance (CCA) class would be created. New expenditures on specific properties would be included in the new class at a 100% rate (instead of 75%) and would be deductible at a 5% declining balance (instead of 7%). The various rules in the Act that apply to a taxpayer's CCA claims would also apply to the new class, including the half-year rule and rules with respect to the recapture of depreciation and the treatment of capital gains.

In addition, special rules would be proposed to deal with the tax treatment of goodwill and other intangibles that were formerly dealt with under the eligible capital property regime, but that do not relate to a specific property. Every business would be deemed for tax purposes to have goodwill associated with it, even if it had not acquired any goodwill. Any capital expenditure that does not relate to a specific property would be added to the capital cost of goodwill and added to the new CCA class. A receipt that did not relate to a specific property would reduce the goodwill balance of the business and of the new CCA class. The reduction would be the lesser of the capital cost of the goodwill (if any) and the amount of the receipt. Any previously deducted CCA would be recaptured and a goodwill reduction that exceeds the capital cost of the goodwill would result in a capital gain.

It is worth noting that the proposed changes may have a material impact on the income tax consequences of a sale of a business structured as a sale of assets as compared to a sale of shares or units of a trust or partnership. Under the proposed rules, proceeds in excess of undepreciated pools, up to historic cost, will result in a 100% income inclusion as opposed to 50% inclusion under the current regime. Furthermore, the portion of proceeds that exceeds historic cost would be taxed as a capital gain, allowing capital losses to be applied against such gains but giving rise to a liability for refundable tax for a taxpayer that is a Canadian-controlled private corporation. Under the current regime, 50% of such amounts are included in income but the rules otherwise applicable to capital gains do not apply.

Budget 2014 also proposes transitional rules to deal with existing CEC pools. A business would be deemed to transfer its existing CEC pool to the new CCA class and, for the first 10 years, the depreciation rate would be 7% in respect of any prior expenditures. Similarly, qualifying receipts which relate to items that were in the CEC pool before the new rules are implemented would only reduce the CCA pool by 75% to avoid an excessive recapture of depreciation previously taken.

Detailed draft legislative proposals will be released for comment at an early opportunity, to be followed by a consultation process.

Clean Energy Equipment: Accelerated Capital Cost Allowance

Currently, Class 43.2 provides accelerated CCA for various types of equipment that generate or conserve energy using renewable sources, waste fuel or particularly efficient use of fossil fuels. Budget 2014 proposes to add water-current energy equipment to Class 43.2. As well, gasification equipment, which is currently included in Class 43.2 when used for certain purposes, will now be included when used in a broader range of applications.

In both cases, qualification under Class 43.2 will depend on the requirements of Canadian environmental laws, by-laws and regulations having been met. This measure will apply to property acquired on or after Budget Day that has not been used or acquired for use before that date.

Employer Source Deductions

In an effort to reduce the tax compliance burden on small employers, Budget 2014 will reduce the frequency of their remittances for employee source deductions. This change will apply to amounts withheld after 2014.

B. TRUST AND ESTATE TAX MEASURES

Kiddie Tax Expansion

The so-called kiddie tax applies the top marginal tax rate to certain amounts paid or payable to an individual under the age of 18. This tax is levied on "split income," which currently includes taxable dividends received (directly or indirectly) on shares that are not mutual fund shares or shares listed on a designated stock exchange, capital gains from dispositions of such shares to a non-arm's length person, and income from a partnership or trust that is derived from providing property or services to a business carried on by certain related persons.

Budget 2014 notes that the kiddie tax does not apply where a minor is allocated income from a partnership or a trust that is derived from business or rental activities conducted with third parties. In order to counter structures that could take advantage of such situations, Budget 2014 proposes an expansion of the definition of "split income" to include business or rental income that is, directly or indirectly, paid or allocated to a minor from a trust or a partnership where a person related to the minor is either (i) actively engaged on a regular basis in the activities of the trust or partnership to earn income from any business or rental property, or (ii) has, in the case of a partnership, an interest in the partnership (whether held directly or through another partnership). This change will be effective for the 2014 and subsequent taxation years.

Flat Rates for Testamentary Trusts

Under the Act trusts are generally subject to tax at a flat rate that corresponds to the highest marginal rate of individual tax. An exception is provided for testamentary trusts and estates and certain grandfathered trusts, which are generally subject to tax on the same graduated tax rates that apply to individuals. Last year's federal budget noted that this potentially allows the beneficiaries of such trusts to access more than one set of graduated rates and questioned the tax fairness of such a result. Accordingly, in June 2013, a consultation process was initiated to explore possible measures to eliminate these benefits.

Following the consultation process, the government has announced in Budget 2014 that, beginning in the 2016 taxation year, testamentary trusts will generally only benefit from graduated tax rates during the first 36 months following death, after which they will be taxed at the highest marginal rate on all of their income. In addition, beginning in 2016, testamentary trusts (other than for during the 36 months following death) will be required to make income tax instalments, will be required to have a calendar year end, and may be liable for alternative minimum tax and Part XII.2 tax, among other changes to the treatment of these trusts.

Individuals should review their tax and estate planning to determine whether changes are necessary as a result of this important measure.

Elimination of Immigration Trusts

The Act contains rules that deem certain non-resident trusts to be resident in Canada, and thus fully liable to Canadian income taxation, if a person that is resident in Canada ever made a contribution to the trust. Under an important exception to these rules, a person that has been resident in Canada for not more than 60 months can generally settle a non-resident trust without having these rules apply. These so-called immigration trusts have long presented a planning opportunity for newly resident Canadians to defer Canadian taxation on foreign assets held in the trust for up to five years after they take up residence in Canada.

Budget 2014 proposes to eliminate the 60-month exemption from the non-resident trust rules, effectively eliminating planning opportunities with immigration trusts. There is only limited grandfathering in respect of this change: an existing immigration trust that currently relies on the exemption will be deemed to be resident in Canada beginning in 2015 provided that no contributions are made to the trust on or after February 11, 2014, and before 2015. If any contributions are made to the trust in that time period, the trust will be deemed to be resident in Canada for any taxation year that ends on or after February 11, 2014.

C. INTERNATIONAL TAX MEASURES

Back-to-Back Loans

Budget 2014 seeks to strengthen the thin-capitalization rules and non-arm's length withholding tax on interest by enacting anti-avoidance rules focused on back-to-back loan arrangements and other specified arrangements. Unfortunately, the proposals, if enacted, would also capture many traditional financing arrangements that do not have a tax-avoidance purpose.

The thin-capitalization rules under the Act restrict the deduction of interest payable by certain corporations and trusts where the amount of debt owing to certain specified non-residents exceeds a 1.5:1 debt-to-equity ratio. Specific anti-avoidance rules currently restrict the ability of a taxpayer to employ "back-to-back" loans in order to circumvent these rules. Budget 2014 will change the conditions in which a back-to-back loan arrangement will be found to exist for purposes of these rules.

Under the Budget 2014 proposals, a back-to-back loan arrangement will exist where: (i) a taxpayer has an outstanding interest-bearing obligation owing to a lender (the intermediary); and (ii) a non-resident person (a) provides security to the intermediary or any person dealing at non-arm's length with the intermediary, (b) is a creditor of the intermediary or any person dealing at non-arm's length with the intermediary under a debt for which recourse is limited to the obligations of the taxpayer, or (c) makes a loan to the intermediary or any person dealing at non-arm's length with the intermediary on condition that a loan be made to the taxpayer. While the Budget Supplementary information refers only to pledges and indicates that a mere guarantee is not targeted, the Notice of Ways and Means Motion explicitly targets any interest or right in property given as security. This would appear to encompass most security arrangements, including those without delivery.

If a back-to-back loan exists, the taxpayer will be deemed to owe an amount to the non-resident person equal to the lesser of the outstanding amount owing to the intermediary and the fair market value of the pledged property or the outstanding amount of the debt for which recourse is limited or the loan made on condition, as the case may be. The taxpayer will also be deemed to have paid interest to the non-resident person in an amount that, broadly speaking, is equal to the proportion of the interest paid or payable on the obligation owing to the intermediary that the deemed amount owing is of that obligation.

Under Part XIII of the Act, withholding tax is applied on interest payments made by a Canadian resident payor to a non resident person if the Canadian resident and the non-resident do not deal at arm's length. There are currently no specific back-to-back loan rules that would apply for the purpose of the withholding tax. As a result of Budget 2014, withholding tax will generally apply in respect of a back-to-back loan arrangement as described above to the extent that the withholding tax would otherwise have been avoided by virtue of the arrangement.

These back-to-back loan arrangement rules will take effect, in the case of the thin-capitalization rules, for taxation years beginning after 2014 and, in the case of non-resident withholding tax on interest, for amounts paid or credited after 2014. It's worth noting that existing arrangements do not benefit from any grandfathering past 2014. Also worth noting is that the above proposals may apply equally to downstream arrangements such as, for instance, where a foreign subsidiary of the Canadian taxpayer provides security in respect of the Canadian taxpayer's indebtedness.

Treaty Shopping

Budget 2013 announced the intention of Finance to combat what Finance referred to as "treaty shopping." In August 2013 Finance released a consultation paper on treaty shopping and invited comments from stakeholders. Finance provided an update of its views on treaty shopping in Budget 2014 and gave details of its preferred approach to dealing with the perceived abuse of Canada's tax treaties.

Budget 2014 indicates that Finance is considering a rule that, subject to certain limitations, would apply to deny treaty benefits that would otherwise be available in respect of certain income earned in Canada (relevant treaty income) where one of the main purposes for undertaking any transaction that results in the treaty benefits was for a person to obtain such benefits. Finance proposed a rule with the following framework:

Main purpose provision – a benefit would not be available under a tax treaty to a person in respect of relevant treaty income if it is reasonable to conclude that one of the main purposes for undertaking a transaction that results in the benefit was for the person to obtain the benefit.

Conduit presumption provision – there would be a rebuttable presumption that one of the main purposes for undertaking a transaction was to obtain a benefit under a tax treaty where the relevant treaty income in respect of which a benefit arises is paid or transferred, directly or indirectly, to a person who would not have been entitled to an equivalent or more favourable benefit if the relevant treaty income had been received directly by that person.

Safe harbour presumption provision – there would be a rebuttable presumption that none of the main purposes for undertaking a transaction was to obtain a benefit under a tax treaty where:

  • the person entitled to the benefit, or a related person, carries on an active business (other than managing investments) in the country with which Canada has concluded the relevant treaty;
  • the person is not controlled by any person who would not have been entitled to equivalent or more favourable benefits had that other person received the relevant treaty income directly; or
  • the person is a publicly traded corporation or trust.

Relieving provision – Notwithstanding that treaty benefits may denied under the main purpose provision, benefits are to be provided to the extent that it is reasonable having regard to all the circumstances. (presumably at the discretion of the Minister).

Some commentators felt that Finance's Budget 2013 anti-treaty shopping initiative and August 2013 consultation paper were largely motivated by official concern at the outcome in three court cases: MIL Investments, Prévost Car and Velcro Canada. Budget 2014 contains examples illustrating the intended application of the proposed treaty-shopping rule, which confirms this view. The fact patterns in the three examples in which benefits are to be denied or limited under the proposed rule are obviously derived from these cases.

Finance's August 2013 paper focused in particular on the use of Canada's treaties with Luxembourg and the Netherlands by entities established by residents of other countries. However, there was no discussion of the government's tax treaty policy, and why certain benefits were negotiated by Canada with Luxembourg and the Netherlands, to give proper definition to the problem of treaty shopping. Moreover, those treaties are commonly used by entities owned by residents of other countries with which Canada has a tax treaty, but Finance did not discuss whether and to what extent it considers this as evidence of treaty abuse.

Interestingly, Canada recently entered into a new protocol to its tax treaty with Luxembourg. Canada presumably had an opportunity to address some of its concerns in the negotiations, but no limitation of benefits measures were included in the protocol.

Finance is proposing a "main purpose" anti-avoidance rule to ensure that it does not inhibit ordinary cross-border trade and investment. Budget 2014 indicates that Finance does not intend this new rule to deny treaty benefits just because one of the considerations in a transaction was the availability of treaty benefits, so long as it was not a "main purpose" for the transaction.

Budget 2014 suggests that the proposed treaty-shopping rule could be adopted unilaterally by Canada by incorporating it into the Income Tax Conventions Interpretation Act. This would make it applicable to all tax treaties to which Canada is a party from the date the rule is enacted.

Finance has invited interested parties to submit comments within 60 days of February 11, 2014, on certain aspects of the proposed rule and on the examples included in Budget 2014. Finance did not indicate a timeline with respect to releasing or enacting legislation. However, Budget 2014 indicates that the recommendations to be made by the OECD in September 2014 concerning approaches to treaty shopping will be relevant in developing the Canadian approach.

New Restrictions on Offshore Entities and Insurance Swaps for FAPI Purposes

Under existing rules, a Canadian resident corporation can establish a foreign affiliate that was a regulated bank, trust company, credit union, insurance corporation or trader or dealer in securities, and, provided that certain additional conditions are satisfied, generally avoid the imposition of foreign accrual property income (FAPI) in respect of such entity's foreign passive income. Budget 2014 proposes to add new conditions that would restrict the ability of all but a select number of taxpayers to establish such entities and avoid FAPI treatment.

The first condition is that the FAPI exception will apply only if the foreign affiliate is the foreign affiliate of (i) a Canadian Schedule I bank, a trust company, a credit union, an insurance corporation or a trader or dealer in securities or commodities resident in Canada, the business activities of which are regulated by the Superintendent of Financial Institutions or a similar authority of a province, (ii) a wholly owned subsidiary of such financial institution or (iii) a corporation that wholly owns such institution (and is also subject to regulation).

The second condition is that, generally, the taxpayer have either (i) $2 billion or more of equity or (ii) more than 50% of the "taxable capital employed in Canada" (for purposes of Part I.3 of the Act) of the taxpayer or of a related Canadian corporation be attributable to a business carried on in Canada that is regulated by the Superintendent of Financial Institutions or a similar authority of a province.

These new conditions will apply starting in 2015.

The government is also changing the FAPI rules to clarify that they will apply to certain captive insurance arrangements involving "insurance swaps" with third parties that indirectly track Canadian risks. Such change shall apply to taxation years that begin on or after Budget Day.

Consultation on Tax Planning by Multinational Enterprises (MNEs)

The government is seeking the views of stakeholders on the impact of international tax planning by MNEs on other participants in the Canadian economy and on related issues, including the effective collection of sales tax on e commerce to residents of Canada by foreign-based vendors.

D. PERSONAL TAX MEASURES

Extension of the Mineral Exploration Tax Credit

Consistent with prior federal budgets, Budget 2014 proposes to extend eligibility for the Mineral Exploration Tax Credit (METC) for one year to individual taxpayers who subscribe for "flow-through shares" pursuant to agreements entered into after March 2014 and on or before March 31, 2015.

The METC generally provides such a taxpayer with a tax credit equal to 15% of "flow-through mining expenditures" renounced to such taxpayer by a corporation carrying on Canadian exploration activities. Budget 2014 amends the definition of flow-through mining expenditure to generally mean certain "Canadian exploration expenses" incurred by such a corporation after March 2014 and before 2016 in conducting mining exploration activity from or above the surface of the earth for the purposes of determining the existence, location, extent or quality of certain mineral resources.

Other Individual Tax Measures

Budget 2014 proposes to:

  • introduce a $450 non-refundable tax credit for search and rescue volunteers who perform at least 200 hours of volunteer search and rescue services in a taxation year;
  • eliminate the requirement for individuals to apply for the GST/HST credit and to allow the CRA to automatically determine the eligibility of individuals for such credit;
  • increase the maximum amount of eligible expenses available for the Adoption Expense Tax Credit from $11,774 to $15,000 for 2014, indexed to inflation for taxation years after 2014;
  • expand the scope of the medical expense tax credit to include costs of designing a therapy plan where the therapy provided under the plan would be eligible for the medical expense tax credit and certain conditions are met, as well as certain expenses for service animals trained to assist individuals with severe diabetes;
  • increase, in certain circumstances, the amount of a lump-sum commutation payment from an underfunded RPP that may be transferred to a RRSP on a tax-free basis;
  • simplify the rules concerning intergenerational transfers of farming and fishing businesses and availability of the lifetime capital gains exemption in respect of dispositions of such businesses;
  • expand the income tax deferral for farmers who dispose of certain breeding livestock; and
  • allow income that is contributed to an amateur athlete trust to qualify as earned income for the purposes of determining the RRSP contribution limit of the trust's beneficiary.

E. CHARITIES AND NOT-FOR-PROFIT TAX MEASURES

Consultation Regarding Non-Profit Organizations (NPOs)

The Act (and its predecessors) has provided a virtually unaltered income tax exemption for NPOs since 1917. Canada Revenue Agency last conducted a comprehensive review of its administrative policy on the NPO tax exemption in the 1992 to 1993 timeframe, but has also since then taken a few high-profile cases to court and has recently undertaken an audit/risk assessment review of the sector.

Budget 2014 announces the most significant development for NPOs in generations. The Department of Finance intends to review the current rules due to apparent concerns that NPOs may be earning profits that are not incidental to carrying out their non-profit purposes, making income available for the personal benefit of members or maintaining disproportionately large reserves.

Finance will issue a consultation paper for public comment. Areas to be addressed include both the NPO tax-exemption status as well as more effective reporting and accountability.

This review will not extend to registered charities or registered amateur athletic associations.

Estate Donations

Budget 2014 proposes amendments to the rules concerning charitable donations made by the estates of deceased persons.

Donations to a charity or other qualified donee made by an estate pursuant to the terms of an individual's will are currently deemed to have been made immediately prior to the individual's death. Budget 2014 proposes instead that the donation will be made by the individual's estate at the time the property is actually transferred to the qualified donee. In addition, the rules will be changed to provide that, where the donation is made within the first 36 months following the individual's death, the trustee of the estate may choose to allocate the donation and the resulting charitable credit among any of: (i) the current taxation year of the estate; (ii) any prior taxation years of the estate; or (iii) the last two taxation years of the individual prior to death, subject to certain existing limitations.

Similar amendments are proposed in respect of donations designated by a deceased individual to be made in respect of property held in certain registered plans, including RRSPs, TFSAs and life insurance policies.

Other Proposed Measures

Budget 2014 also proposes to:

  • extend the carry-forward period in respect of credits arising in connection with donations of ecologically sensitive land from five years to 10 years;
  • tighten the rules that apply to charitable gifts of property acquired as part of a tax shelter gifting arrangement; and
  • provide the Minister with discretion to revoke the registration of charitable organizations that are in receipt of funds from foreign states that support terrorism.

F. GST/HST MEASURES

Closely Related Group Exemption

The Excise Tax Act (ETA) provides for a group relief election allowing qualifying members of a closely related group to make supplies of certain goods or services among them without GST/HST.

The rules determining whether taxpayers will be qualifying members of a closely related group for these purposes are detailed and subject to numerous exceptions, but generally include corporations and partnerships engaged exclusively in commercial activities and connected by a significant degree of ownership or control. Qualifying members are currently not required to file the group relief election, but should keep it in case of audit.

Budget 2014 proposes to eliminate a technical limitation with respect to newly formed corporations and/or partnerships by expanding the definition of a qualifying member of a closely related group to include a registrant that has not yet acquired property and made taxable supplies provided it is reasonable at the election time to expect that the registrant will make taxable supplies throughout the next 12 months and will carry on commercial activities.

Budget 2014 also proposes to amend the closely related group rules by:

  • requiring that the qualifying members file their group relief election with the CRA; and
  • holding qualifying members to an existing or new group relief election jointly and severally liable with respect to any liability for GST/HST that may arise in connection with supplies made among them on or after January 1, 2015.

Joint Ventures

Under the ETA, parties to certain joint ventures may file an election allowing them to appoint one person as being responsible for accounting for the GST/HST obligations resulting from the joint venture activities, greatly simplifying the compliance burden. Current rules provide that only certain joint ventures undertaken with respect to a limited number of activities are eligible to benefit from this election. Budget 2014 will make this election available to a much broader range of joint ventures engaged exclusively in commercial activities.

Draft legislation with respect to joint ventures is expected to be released later this year.

Expansion of Health-related Services

Budget 2014 includes proposals to expand the scope of goods and services supplied in the health care sector that will be exempted from or zero-rated in respect of GST/HST, including the following:

  • the design and development of certain training plans to assist individuals in coping with disorders or disabilities will be exempted where the training itself would be exempt from GST/HST under existing rules;
  • professional services rendered by acupuncturists and naturopathic doctors will be exempted;
  • prescribed eyewear specially designed to treat or correct a defect of vision by electronic means will be zero rated.

Forced Registration

Budget 2014 proposes to amend the ETA by providing the Minister with discretion to cause registration of a person for GST/HST where the person fails to comply with a requirement to register.

G. UPDATES AND PREVIOUSLY ANNOUNCED MEASURES

Budget 2014 provided an update on the government's compliance with OECD standards for tax information exchanges with other countries, including with respect to the US Foreign Account Tax Compliance Act (FATCA), details of which were announced in early February. As well, Budget 2014 confirmed the government's intention to proceed with a number of outstanding previously announced initiatives including:

  • automobile expense amounts previously announced (December 29, 2011, and December 28, 2012);
  • legislative proposals for banks with foreign affiliates (November 27, 2012);
  • legislative proposals for technical income tax, excise duties and sales tax amendments (July 12, 2013);
  • legislative proposals relating to the foreign affiliate dumping rules (August 16, 2013);
  • legislative proposals related to life insurance policyholder exemption (August 23, 2013);
  • legislative proposals relating to the tax rules governing labour-sponsored venture capital corporations (November 27, 2013);
  • legislative proposals requiring that international electronic funds transfers of $10,000 or more be reported to the CRA (January 9, 2014);
  • proposed changes to GST/HST rules to prevent input tax credit claims exceeding tax actually paid (January 17, 2014) and relating to a GST/HST exemption for hospital parking (January 24, 2014);
  • legislative proposals related to caseload management of the Tax Court of Canada (June 8, 2012); and
  • legislative proposals regarding specified flow-through entities, real estate investment trusts and publicly traded corporations (July 25, 2012).

Footnote

1 Unless otherwise specified any statutory references contained herein are references to the Act.

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