A discussion on some of the more "unexpected and unusual elements" in Finance Canada's 947-page Notice of Ways and Means Motion that are "likely to affect the provision of future income tax advice."

The thin capitalization rules are designed to protect the Canadian tax base from erosion through excessive interest deductions in respect of debt owing by Canadian taxpayers to certain non-resident shareholders.

On October 31, 2011, the Department of Finance proposed changes to the Income Tax Act that effectively put an end to the potentially advantageous tax planning strategy of having an employee agree to provide their services to their employer through a corporate entity (a "Personal Services Business").