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Recent Publications - Corporate finance

Recent Publications

January 15, 2024

2024 tax deadline calendar

Navigating the various Canadian and U.S. tax deadlines throughout the year can be tricky. Our 2024 tax deadline calendar provides a monthly snapshot of important dates that could apply to you or your organization. It can help you stay on top of your obligations, discover overlooked deadlines and avoid unwanted surprises.

July 26, 2023 by Mike Hayward, Dean Morris

BT Canada offers recommendations on transfer pricing reform

At Baker Tilly Canada, we are committed to helping ensure fairness and integrity in the Canadian tax system.

As part of this commitment, we are grateful for the opportunity to provide our input on the Department of Finance consultation paper regarding reform and modernization of Canada’s transfer pricing rules.

March 15, 2023

Federal Court of Appeal reaffirms application of anti‑avoidance rule in Foix decision

In Foix v. The King, 2023 FCA 38, the Federal Court of Appeal (FCA) ruled that a distribution of funds following a hybrid sale was subject to the application of subsection 84(2) of the Income Tax Act (ITA), affirming the Tax Court of Canada (TCC) ruling, Foix v. The Queen, 2021 TCC 52.

January 18, 2023

2023 tax deadline calendar

With so many Canadian and U.S. tax deadlines spread throughout the year, everyone could use an occasional reminder. Our 2023 tax deadline calendar provides a convenient month‑by‑month summary of key dates that could apply to you. You might even notice a few obligations that slipped your mind. If you don’t like getting caught by surprise, you’ll love our tax deadline calendar.

October 25, 2022

To file or not to file – Considerations for late‑filed GST/HST section 156 elections

GST/HST is generally applicable when property and/or services destined exclusively for commercial purposes are supplied by a closely related party who is registered for that tax. To simplify tax accounting and improve cashflow, certain closely related Canadian corporations and partnerships can elect under subsection 156(2) of the Excise Tax Act, via Form RC4616, to treat certain supplies by a closely related person as if they were made without consideration.

April 26, 2022 by Mandeep Gaheer, Hassanatu Timbo

Budget 2022: Adapting international tax measures

Canada is one of 137 members of the Organization for Economic Cooperation and Development (OECD) that have joined the two-pillar plan for international tax reform. Budget 2022 reiterates the government’s commitment to address the challenges arising from the digitalization of the economy, and to work towards implementing both Pillar One and Two.

November 23, 2021

Sourcing and closing better deals with PitchBook

In its role as a financial advisor, Baker Tilly Canada Capital Corporation (BTCC) helps small- to mid-size companies execute sell-side, buy-side and valuation engagements. 

September 21, 2021

The profits and pitfalls of maintaining QSBC share status

With the recent Royal Assent of Bill C-208, owners of incorporated small and medium-sized businesses, and their tax advisors, were reminded that proactively monitoring and maintaining qualifying small business corporation (QSBC) share status is essential to make many tax-planning strategies possible. There are many traps that may cause the unintended loss of QSBC share status, and when the time comes to take advantage of available tax planning, it can be too late to correct the problem.

July 30, 2018 by Bob Boser

Avoiding and Getting Off of The TOSI Highway

On July 18, 2017 the Federal Finance Minister announced proposals to change the tax rules related to income splitting using private corporations. The original proposals were subsequently withdrawn in October, re-released in December and after further changes the proposed legislation was included in Bill C-74 in March 2018. Bill C-74 received Royal Assent on June 21, 2018 and the new tax on split income (TOSI) rules are now in effect as of the beginning of 2018.

March 14, 2018 by Martha MacRae, Todd King

U.S. Tax Reform Punishes U.S. Citizens Abroad

From a taxation perspective, the period from July 2017 to February 2018 has been one of the most tumultuous in recent history for Canadian private company owners. For those who also have the privilege of being U.S. citizens or resident aliens, things have gotten downright ludicrous. In a rush to pass into law the most sweeping tax reform in a generation, U.S. lawmakers have stuck U.S. citizens resident in Canada with retroactive, double taxation, the elimination of much of the tax deferral previously available in their companies, a looming April 17th payment deadline and virtually no rules or regulations to guide them through the chaos.

February 27, 2018

Commentary

The Honourable Bill Morneau, Minister of Finance, today tabled his third budget – “Equality + Growth: A Strong Middle Class” – which supports the Government’s people centered approach. 

The highly anticipated budget released draft legislation related to passive income – the topic that has been on the minds of business owners, investors, and advisors since the July 18, 2017 Finance release which first introduced the subject.  The budget does not propose changes to tax rates at the business or personal level. The budget focused on five key spending areas – growth, progress, reconciliation, advancement and equality.

December 19, 2017 by Guy Desmarais

Just a spoonful of TOSI may help the medicine go down

The Department of Finance released its long-awaited proposed amendments to the tax on split income (TOSI) rules on December 13. The release completes a tumultuous year for small business owners, tax professionals, Department of Finance officials, Members of Parliament and the Minister of Finance. The initial July 18 proposals and the short consultation period precipitated a groundswell of consternation and frustration. 

December 14, 2017 by Heather Forbes

Amendments to the Income Tax Act and status of proposed measures

On December 13, 2017, Amendments to the Income Tax Act and Regulations and Explanatory Notes to simplify measures to restrict income sprinkling were released by Finance Canada. Today’s Tax Flash will focus on the changes to the July 18 proposals, exclusions, reasonableness test and a brief update on the status of the proposed measures related to passive investments.

October 20, 2017 by Derek de Gannes

Venture Capital concerns are heard

On October 20, 2017, the Department of Finance (“Finance”) responded to several concerns raised by the venture capital and angel investor sectors in respect of the proposed taxation of private corporation measures (see CBT’s summary here).