The federal budget (Budget 2018) tabled on February 27 (Budget Day) contains a number of proposed amendments to Canada's Income Tax Act (Tax Act). This bulletin focuses on certain (i) business income tax measures; (ii) international tax measures, (iii) sales and excise tax measures and (iv) personal income tax measures, proposed therein.
Business Income Tax Measures
Passive Investment Income
In July 2017, the Department of Finance (Finance) launched public consultations to address a perceived deferral advantage available to shareholders of private corporations. Finance was of the view that it was inappropriate for a private corporation to use its retained earnings derived from active business, which have been taxed at preferential corporate income tax rates, to finance passive investments held within the corporation. Considering the feedback received from stakeholders during the consultation period, Budget 2018 proposes two tax measures intended to limit such deferral advantage in respect of passive investment income earned by private corporations.
1. Business Limit
The federal corporate income tax rate for Canadian-controlled private corporations (CCPCs) is currently 10.5% (small business rate) for qualifying active business income up to $500,000 (the business limit). A CCPC is required to share the business limit with associated corporations. Finance had previously proposed to reduce the small business rate to 10% for 2018 and to 9% effective 2019 to increase the availability of after-tax income for reinvestment in the active business.
Budget 2018 proposes to reduce the business limit on a straight-line basis for CCPCs with passive investment income (earned by the CCPC and any associated corporations with which it shares the business limit) between $50,000 and $150,000. Business income earned by the CCPC above the reduced business limit will be taxed at the general corporate income tax rate rather than the small business rate. This measure is proposed to apply along with an existing rule that reduces the business limit where a CCPC (together with associated corporations) has taxable capital in excess of $10 million. The reduction in the CCPC's business limit will be the greater of the reduction under the proposed measure and the existing rule.
For the purposes of this proposed measure, investment income will be calculated using the existing concept of aggregate investment income used in the Tax Act, with the following adjustments:
- Taxable capital gains (and allowable capital losses) arising from the following transactions will generally be excluded:
- disposition of property used principally in a Canadian active business by the CCPC or a related CCPC;
- disposition of shares of another connected CCPC where all or substantially all of the value of the other CCPC is attributable to assets used in a Canadian active business and certain other conditions are met;
- net capital losses carried over from other tax years will be excluded;
- dividends from non-connected corporations will be added; and
- to the extent not already included in aggregate investment income, income from savings in a life insurance policy (other than an exempt policy) will be added.
Investment income that is incidental to an active business is generally considered to be active business income and, therefore, would not be included in such adjusted aggregate investment income.
2. Refundable Taxes on Investment Income
Under the current tax system, passive investment income earned in a private corporation is generally subject to income tax at a rate that approximates the top personal income tax rate. A portion of this tax is generally added to the corporation's refundable dividend tax on hand (RDTOH) account and refunded to the corporation when paid out as taxable dividends to shareholders. A corporation can pay an eligible dividend (generally in respect of business income that was taxed at the general corporate rate) or a non-eligible dividend (generally in respect of most types of passive investment income and business income that was taxed at the lower small business rate). A corporation may receive a refund of taxes out of its RDTOH account, regardless of whether it pays eligible or non-eligible dividends. An individual receiving an eligible dividend is entitled to an enhanced dividend tax credit, whereas an individual receiving a non-eligible dividend is entitled to the ordinary dividend tax credit. Finance takes the view that this mechanism allows a private corporation to generate a refund of taxes paid on passive investment income by paying an eligible dividend sourced from general rate business income, thus creating a deferral advantage in respect of passive investment income.
Budget 2018 proposes to limit the availability of a refund of a private corporation's RDTOH where it pays non-eligible dividends. There will be an exception for RDTOH that arises from eligible portfolio dividends, which will necessitate the creation of a new account (eligible RDTOH) that tracks refundable taxes paid under Part IV of the Tax Act on eligible portfolio dividends. The corporation's existing RDTOH account (non-eligible RDTOH) will track refundable taxes paid under Part I of the Tax Act on investment income and under Part IV of the Tax Act on non-eligible portfolio dividends. Refunds from eligible RDTOH will be obtained upon the payment of any taxable dividends, whereas refunds from non-eligible RDTOH will be obtained only upon the payment of non-eligible dividends. Even though a non-eligible dividend can give rise to refunds from both non-eligible RDTOH and eligible RDTOH, a corporation will first be required to obtain a refund from its non-eligible RDTOH before its eligible RDTOH.
Where a corporation receives a dividend from a connected corporation and RDTOH is refunded to the payor corporation in respect of that dividend, the recipient corporation pays a refundable tax under Part IV of the Tax Act that is added to the recipient corporation's RDTOH account. Under the proposed measure, the amount added to the recipient corporation's RDTOH account will match the RDTOH account from which the refund was paid to the payor corporation.
This proposed measure also includes a transitional rule setting out the manner in which to allocate a private corporation's existing RDTOH to its eligible RDTOH and non-eligible RDTOH. The allocation method differs for CCPCs and non-CCPCs.
Anti-avoidance measures are also proposed to be put in place to prevent transactions designed to avoid the above measures, such as the creation of a short taxation year to defer application of the proposed rules.
Each of the proposed measures described above will apply to taxation years that begin after 2018.
Tax Support for Clean Energy
Currently, certain specified clean energy generation and conservation equipment acquired before 2020 qualifies for accelerated capital cost allowance.
Budget 2018 proposes to extend this treatment by five years to such equipment acquired before 2025.
Artificial Losses Using Equity-Based Financial Arrangements
Under typical securities lending and repurchase transactions, a person (lender) transfers a security (e.g., a Canadian share) to a taxpayer (borrower), and the borrower agrees to redeliver an identical security to the lender in the future. Over the term of the arrangement, the borrower is obligated to pay to the lender compensation payments for all income (i.e., dividends) received on the transferred security (i.e., the Canadian share).
According to Budget 2018, Finance became aware of certain taxpayers entering into certain types of securities lending and repurchase arrangements involving Canadian shares that purportedly attempted to achieve the same tax benefit that was targeted by the synthetic equity arrangement rules. One such type of transaction appears to involve a borrower (not a registered securities dealer) borrowing and holding Canadian shares under a securities loan that purposely does not qualify as a "securities lending arrangement" as defined in the Tax Act. The borrower receives a dividend on the share it holds and takes the position that it is entitled to deduct the amount of the dividend compensation payment to the lender as well as to take the inter-corporate dividend deduction equal to the amount of the dividend received (presumably on the basis that the dividend rental arrangement rules do not apply).
Budget 2018 proposes to add a definition called "specified securities lending arrangement" which is an arrangement substantially similar to a "securities lending arrangement." This is intended to ensure taxpayers that enter into arrangements substantially similar to securities lending arrangements are subject to several provisions normally applicable to such arrangements. As a result of this amendment, when a taxpayer receives dividends on a Canadian share acquired under such a substantially similar arrangement, the dividend rental arrangement rules will generally apply to deny the inter-corporate dividend deduction.
Budget 2018 also proposes an amendment to clarify the interaction of two rules governing the deductibility of dividend compensation payments made by a borrower under a securities lending transaction. Under the first rule, a registered securities dealer is permitted to deduct two-thirds of a dividend compensation payment made to a lender. Under the second rule, which contemplates a securities lending arrangement being a type of dividend rental arrangement, the taxpayer, whether or not it is a registered securities dealer, is permitted to fully deduct any dividend compensation payment made to the lender. The proposed amendment will clarify that the first rule does not apply when the second rule applies.
The amendments will apply to dividend compensation payments that are made on or after Budget Day, unless the securities lending arrangement was in place before Budget Day, in which case the amendments will apply to dividend compensation payments that are made after September 2018.
Budget 2018 proposes to further revise the synthetic equity arrangement rules which were originally introduced in the 2015 federal budget. In its current form, these rules do not apply where the taxpayer establishes that no tax-indifferent investor has all or substantially all of the risk of loss and opportunity of gain or profit in respect of a Canadian share by virtue of a synthetic equity arrangement or a specified synthetic equity arrangement. The proposals clarify that this exception is not available when a tax-indifferent investor obtains all or substantially all of the risk of loss and opportunity for gain or profit in respect of the share in any way, including where the tax-indifferent investor has not entered into a synthetic equity arrangement or a specified synthetic equity arrangement in respect of the share.
Stop-Loss Rule on Share Repurchase Transactions
The 2011 federal budget amended the dividend stop-loss rules pertaining to shares held by a taxpayer as mark-to-market property where the taxpayer was deemed to have received a dividend resulting from a sale of the share to the issuer, for example, under a private agreement (and where such deemed dividend was deductible to the taxpayer in computing its taxable income). As amended, the rule generally denied the portion of the loss for tax purposes realized on the repurchase equal to the excess of the original cost of the shares over their paid-up capital. The portion of the loss for tax purposes equal to net mark-to-market gains previously included in computing the taxpayer's income was generally allowed under the rules.
Budget 2018 proposes to amend the rule so that the loss for tax purposes as otherwise realized on a share repurchase (as described above) is generally denied by the deductible dividends received on the share (including deemed dividends received on the repurchase). Pursuant to the proposal, the taxpayer's proceeds of disposition (as otherwise determined) will generally be increased by the amount of deductible dividends on the share (including deemed dividends) where the taxpayer received a deemed dividend in a share repurchase transaction. Previously, the upward adjustment to proceeds of disposition was the lesser of such deductible dividends and the loss on the share based on the taxpayer's original cost.
The measure will apply in respect of share repurchases that occur on or after Budget Day.
At-Risk Rules for Tiered Partnerships
Budget 2018 proposes to clarify the application of the at-risk rules to tiered partnership structures.
Under the at-risk rules, limited partners of a partnership may deduct losses allocated to them from the partnership only to the extent of their at-risk amount in respect of the partnership. Conceptually, a limited partner's at-risk amount in respect of its partnership interest reflects the limited partner's invested capital that is at risk in the partnership. Losses of a partnership allocated to a limited partner in excess of their at-risk amount are not deductible and become limited partnership losses, which are generally eligible for an indefinite carryforward. The long-standing position of the CRA has been that these rules apply to a limited partner that is itself a partnership (a tiered partnership structure) with the result that limited partnership losses are not eligible to be carried forward by such limited partners.
However, a recent Federal Court of Appeal decision (Canada v. Green, 2017 FCA 107) constrained the application of the at-risk rules in tiered partnership structures in a manner that, according to Finance, is inconsistent with the underlying policy of the rules.
Budget 2018 proposes to amend the at-risk rules to clarify that they apply to a partnership (top partnership) that is itself a limited partner of another partnership (bottom partnership). In particular, the amount of losses of the bottom partnership that can be allocated to the top partnership's members will be restricted by the top partnership's at-risk amount in respect of the bottom partnership. Further, any losses of the bottom partnership that would otherwise be allocated to the top partnership in excess of its at-risk amount will not be a limited partnership loss of the top partnership. Instead, any such excess will be reflected in the adjusted cost base of the top partnership's interest in the bottom partnership.
This measure will apply in respect of taxation years ending on or after Budget Day. However, losses from a partnership incurred in a taxation year that ended prior to Budget Day will generally not be available to be carried forward to a taxation year that ends on or after Budget Day if the losses were allocated to a limited partner that is another partnership.
International Tax Measures
Cross-Border Surplus Stripping Using Partnerships and Trusts
The paid-up capital of a Canadian corporation, which generally represents the amount of capital contributed to the corporation by its shareholders is, in a cross-border context, a valuable tax attribute in that it can typically be returned by the Canadian corporation to its non-resident shareholders without attracting non-resident withholding tax and is reflected in equity for the purpose of the thin-capitalization rules. The Tax Act contains a cross-border anti-surplus stripping rule which is intended to prevent non-resident shareholders from extracting surplus of a Canadian corporation in excess of its paid-up capital, or artificially inflating the paid-up capital of a Canadian corporation, free of non-resident withholding tax. This rule generally applies when a non-resident person, or a partnership with certain non-resident members, transfer shares of one Canadian corporation to another Canadian corporation with which the non-resident shareholder does not deal at arm's length in exchange for shares or other forms of consideration.
The current anti-surplus stripping rule does not expressly apply when a non-resident shareholder disposes of an interest in a partnership that in turn owns shares of a Canadian corporation. Budget 2018 notes that certain taxpayers have taken advantage of this aspect of the rule by engaging in internal reorganizations where a non-resident person transfers shares of a Canadian corporation to a partnership in exchange for a partnership interest, following which the non-resident person transfers the partnership interest to another Canadian corporation. Finance is concerned with variations of this partnership planning, as well as similar arrangements involving trusts, both in the context of the cross-border anti-surplus stripping rule, as well as a similar rule that applies to corporate immigrations.
To ensure that the underlying purpose of the cross-border anti-surplus stripping rule and the corresponding corporate immigration rule cannot be frustrated by transactions involving partnerships and trusts, Budget 2018 proposes to expand the scope of these rules. The expansion of scope is proposed to add comprehensive look-through rules for these entities that will allocate the assets, liabilities and transactions of a partnership or trust to its members or beneficiaries, as the case may be, based on the relative fair market value of their interests.
This proposed measure will apply to transactions that occur on or after Budget Day.
As a supporting measure, Budget 2018 also includes draft legislation to ensure that contributed surplus of a corporation that arises when it is a non-resident corporation, or in connection with a disposition that is subject to the cross-border surplus stripping rule, may not be converted into paid-up capital or included in equity for purposes of the thin-capitalization rules. These proposals will apply to transactions or events that occur on or after Budget Day.
A Canadian taxpayer is generally required to include in its income for a taxation year any foreign accrual property income (FAPI) earned by a controlled foreign affiliate of the taxpayer in such taxation year, whether or not that income is distributed to the taxpayer. In contrast, no such accrual is required in respect of active business income of a foreign affiliate. Generally, a non-resident corporation will be a foreign affiliate of a Canadian taxpayer if the taxpayer has an equity interest in the non-resident corporation of at least 10% and a foreign affiliate will be a controlled foreign affiliate of the Canadian taxpayer if the taxpayer has a controlling interest in the foreign affiliate.
In response to Finance's ongoing monitoring in the foreign affiliate area, Budget 2018 contains a number of measures to strengthen Canada's international tax rules and detailed legislation to implement these measures will follow at a later date.
1. Investment Business
Generally, income from an active business of a foreign affiliate is excluded from FAPI. However, if the principal purpose of the business is to earn income from certain passive sources, such as interest, dividends or rents, the business will be considered to be an investment business and income from that business will be included in the foreign affiliate's FAPI. Notwithstanding, a business will be excluded from the investment business definition if certain conditions are satisfied, including that the affiliate employs more than five full-time employees in the active conduct of the business (the six employees test). This condition must be satisfied on a business-by-business basis.
Budget 2018 notes that certain taxpayers whose foreign activities do not warrant more than five full-time employees are grouping their financial assets with other taxpayers in similar circumstances into a common foreign affiliate and taking the position that the affiliate is carrying on a single business, such that it meets the six employees test. Further, to effect this planning, these arrangements typically ensure that each taxpayer retains control over the assets it contributes to the affiliate and that the returns earned by the affiliate are separately tracked to the various assets and accrue to the benefit of the particular contributing taxpayer. Budget 2018 states that it is not intended that taxpayers be permitted to satisfy the six employees test in these types of tracking arrangements, since the assets of each taxpayer are not truly pooled (that is the economic outcome of each taxpayer remains unchanged), and the affiliate is essentially used as a conduit entity to shift passive income offshore.
To ensure that the investment business definition operates as intended, Budget 2018 proposes to amend that definition so where income of a foreign affiliate that is attributed to specific activities accrues to the benefit of a specific taxpayer under such a tracking arrangement, those activities will be deemed to be a separate business carried on by the affiliate. Each separate business will be required to meet the six employees test, and the other conditions in the investment business definition, in order for the income from that business to be excluded from the affiliate's FAPI.
This measure is proposed to apply to taxation years of a foreign affiliate that begin on or after Budget Day.
2. Controlled Foreign Affiliate Status
A Canadian taxpayer is required to include FAPI of a non-resident corporation only if that non-resident corporation is a controlled foreign affiliate of the taxpayer. Budget 2018 notes that tracking arrangements are also being used by certain sufficiently large groups of Canadian taxpayers to avoid controlled foreign affiliate status and FAPI accruals.
Budget 2018 proposes to deem a foreign affiliate of a taxpayer to be a controlled foreign affiliate of the taxpayer if FAPI attributable to activities of the affiliate accrues to the benefit of the taxpayer under a tracking arrangement.
This measure is proposed to apply to taxation years of a foreign affiliate that begin on or after Budget Day.
3. Trading or Dealing in Indebtedness
Income from a business carried on by a foreign affiliate, the principal purpose of which is to derive income from trading or dealing in indebtedness, is generally treated as FAPI of the affiliate except where the affiliate is a qualifying regulated foreign financial institution (RFFI). A similar exception is provided under the existing investment business rules which currently require that a taxpayer satisfy certain minimum capital requirements. Budget 2018 proposes to impose similar minimum capital requirements to the trading or dealing in indebtedness exception for RFFIs, to ensure consistency among the two rules. This measure is proposed to apply to a foreign affiliate's taxation years that begin on or after Budget Day.
To give more time to the Canada Revenue Agency to conduct audits in respect of foreign affiliates (considering that such audits often involve requesting information through a tax treaty or tax information exchange agreement), Budget 2018 proposes to extend the reassessment period by three years for a taxpayer with respect to income arising in connection with a foreign affiliate. This measure is proposed to apply to a taxpayer's taxation years that begin on or after Budget Day.
5. Reporting Requirements
Budget 2018 proposes to change the information return deadline for providing information regarding foreign affiliates and amounts included in (or excluded from) FAPI. Budget 2018 proposes to move this deadline to match the corporate income tax return deadline, effectively requiring the information return to be filed within six months of the taxpayer's taxation year end. This proposal would move up the deadline to file the information return by nine months for corporate taxpayers which may become extremely challenging. The new deadline would only apply to the taxpayer's taxation years beginning after 2019.
1. Requirements for Information and Compliance Orders
CRA generally has wide-ranging powers to gather information regarding taxpayers in the audit process, including issuing requirements for information and obtaining compliance orders. The impact on the reassessment period when making use of information gathering tools is different for requirements for information and compliance order challenges involving foreign-based information and challenges not involving foreign-based information. If there is a challenge to a requirement for foreign-based information, the period open for reassessment by CRA is extended by the amount of time during which the requirement is contested. On the other hand, the rules do not give CRA added time where a requirement is contested for information that is not foreign-based.
Budget 2018 proposes to afford greater flexibility to CRA so that CRA does not become statute-barred from reassessing a taxpayer while a requirement for information or a compliance order is being contested. This proposal would amend the Tax Act such that the reassessment periods would be extended with a stop-the-clock extension of time for requirements for information (generally) and compliance orders. The clock would be stopped on the reassessment periods until final resolution of a contested requirement for information and compliance order, whether the information sought is foreign-based or not.
This proposed measure would apply for challenges instituted after the enacting legislation comes into effect.
2. Non-Resident Non-Arm's Length Persons
The reassessment period for a resident taxpayer is generally three or four years. Where a taxpayer enters into a transaction with a non-resident person with which it does not deal at arm's length, the reassessment period is extended by three years.
If the taxpayer has a loss in the current year and that loss is carried back to a prior year, the CRA has an additional three years to reassess that prior year. This rule, however, does not consider the extended three-year period in the case of transactions with non-arm's length non-residents, hampering the CRA's ability to issue consequential reassessments for prior tax years.
Budget 2018 proposes to extend the reassessment period for a prior tax year of a taxpayer by an additional three years to the extent the reassessment relates to the adjustment of a loss carryback, where:
- a reassessment of a taxation year is made as a consequence of a transaction involving a taxpayer and a non-resident person with whom the taxpayer does not deal at arm's length;
- the reassessment reduces the taxpayer's loss for the year that is available for the carryback; and
- all or any portion of that loss had in fact been carried back to the prior taxation year.
This measure would apply to taxation years in which a carried back loss is claimed where such loss arises in a taxation year ending on or after Budget Day.
Other International Measures
In Budget 2018, Finance states that it remains committed to safeguarding Canada's tax system and has been actively involved in the Base Erosion and Profit Shifting (BEPS) project undertaken by the Organization for Economic Co-operation and Development (OECD)/G20. Ongoing initiatives in the international tax avoidance and BEPS area include:
- taking steps in 2018 to enact the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) into Canadian law and ratify the MLI as needed to bring it into force;
- adopting new rules into Canada's tax treaties to address treaty abuse, either through the MLI or as part of negotiating new, or renegotiating existing, tax treaties;
- expanding and updating Canada's network of treaties and tax information exchange agreements;
- continuing to work with international partners to improve international dispute resolution and ensure a coherent and consistent response to fight cross-border tax avoidance;
- participating in developing additional guidance on issues relating to the OECD's Transfer Pricing Guidelines, which guidance is expected to be published over the course of 2018; and
- continuing to monitor the foreign affiliate rules to ensure their effectiveness.
Sales and Excise Tax Measures
GST/HST and Investment Limited Partnerships
On September 8, 2017, Finance released draft legislative and regulatory proposals (GST/HST proposals) relating to the application of GST/HST to investment limited partnerships (ILPs) as defined therein.
Under the GST/HST proposals:
- GST/HST would be payable on the fair market value of management and administrative services provided to an ILP by the general partner of the ILP where consideration becomes due or is paid on or after September 8, 2017;
- ILPs would be investment plans and would be subject to special GST/HST rules applicable to investment plans effective January 1, 2019; and
- GST/HST relief would be provided to ILPs with non-resident investors where certain conditions are met.
Budget 2018 confirms Finance's intention to proceed with the GST/HST proposals, subject to the following modifications:
- GST/HST will apply to management and administrative services rendered by the general partner on or after September 8, 2017 and not to management or administrative services rendered by the general partner before September 8, 2017 unless the general partner charged GST/HST in respect of such services rendered before that date. Further, GST/HST is payable on the fair market value of such services in the period in which such services are rendered; and
- an election will be available to an ILP to advance the application of the special GST/HST rules for investment plans as of January 1, 2018.
Consultations on the GST/HST Holding Corporation Rules
Budget 2018 announces Finance's intention to consult on certain aspects of a GST/HST rule that generally allows a parent corporation to claim input tax credit (ITCs) to recover GST/HST it pays on expenses that relate to another corporation (holding corporation rule). Under the holding corporation rule, where a parent corporation resident in Canada incurs expenses that relate to shares or indebtedness of a related commercial operating corporation (a corporation all or substantially all of the property of which is for consumption, use or supply in commercial activities), the expenses are generally deemed to have been incurred in commercial activities of the parent corporation. The consultation will examine the limitation of the holding corporation rule to corporations as well as the required degree of relationship between the parent and the commercial operating company. At the same time, Finance intends to clarify which expenses of the parent corporation qualify for input tax credits under the holding corporation rule.
Budget 2018 states that consultation documents and draft legislative proposals regarding these matters will be released for public comment in the near future.
Personal Income Tax Measures—Reporting Requirements for Trusts
Prior to Budget 2018, a trust generally would have been required to file an annual T3 return only if it earned income or made a distribution in a year. Budget 2018 proposes that express trusts (which are created with the settlor's express intent, usually in writing) resident in Canada and certain non-resident trusts be mandated to file T3 returns, detailing the identity of all trustees, beneficiaries and settlors of the trust, and those with any control over decisions by the trustee concerning the appointment of income or trust capital. This new reporting requirement would not apply to a resulting or constructive trust.
Budget 2018 lists several exceptions to this new reporting requirement, including for mutual fund trusts, segregated funds and master trusts, trusts governed by registered plans, lawyers' general trust accounts and trusts that qualify as non-profit organizations or registered charities. Budget 2018 also creates an exception for trusts with less than $50,000 in assets throughout the taxation year, where the holdings are deposits, government debt obligations or listed securities and trusts that have been in existence for less than three months.
New penalties of up to $2,500 will be imposed for failure to file a T3 return where required. In a case where the taxpayer was grossly negligent or knowingly failed to file, additional penalties, if assessed, would be equal to 5% of the fair market value of the property held by the trust in the relevant year (with a minimum penalty of $2,500). These penalties would be in addition to the existing penalties. The proposed reporting and additional penalty rules would apply for returns required to be filed for 2021 and subsequent taxation years.
Status of Outstanding Tax Measures
Budget 2018 confirms the government's intention to proceed with certain tax and related measures (as modified to take into account consultations and deliberations since their announcement or release), including:
- measures to address income sprinkling (released on December 13, 2017);
- remaining proposals relating to the GST/HST (released on September 8, 2017);
- measures on information reporting requirements for certain dispositions of an interest in a life insurance policy (announced in 2016 federal budget); and
- measures expanding tax support for electric vehicle charging stations and electrical energy storage equipment (announced in 2016 federal budget).
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