Bill C-47, which implements certain outstanding tax measures announced in the 2021, 2022, and 2023 federal budgets and 2022 federal economic update, along with previously announced technical amendments, passed third reading in the House of Commons on June 8, 2023. The bill includes the denial of a deduction for dividends received where financial institutions enter into certain transactions involving hedging and short selling arrangements, as well as expanded mandatory disclosure rules and new reporting requirements for digital platform operators, among other business, personal and indirect tax measures. Bill C-47 received first reading on April 20, 2023.
Note that the corporate income tax measures included in Bill C-47 are considered substantively enacted for IFRS and Accounting Standards for Private Enterprise (ASPE) purposes on June 8, 2023 (the date the bill passed third reading), as Canada has a minority government. The corporate income tax measures in Bill C-47 will be considered enacted for U.S. GAAP purposes on the date the bill receives Royal Assent.
Business tax measures
The bill includes some of the outstanding business tax measures from the 2021 and 2022 federal budgets, including changes related to:
- Mandatory disclosure rules
- Reporting rules for digital platform operators
- Hedging and short selling by Canadian financial institutions
- Borrowing by defined benefit pension plans
- Reporting requirements for Registered Retirement Savings Plans (RRSPs) and Registered Retirement Income Funds (RRIFs).
Other tax measures
The bill also includes certain indirect tax measures from the 2023 federal budget, as well as other previously announced measures, affecting the GST/HST treatment of payment card clearing services, pension plans and crypto asset mining. In addition, the bill includes some of the personal tax measures from the 2023 federal budget and 2022 federal fall economic update, such as extension of the residential property flipping rule to assignment sales, changes related to Registered Education Savings Plans (RESPs) and Registered Disability Savings Plans (RDSPs) and an increase to the deduction for tradespeople’s tool expenses. The bill also contains administrative tax measures (e.g., related to electronic filing and certification of tax and information returns) and other previously announced technical amendments (e.g., related to changes to Canadian exploration expenses).
For more information, contact your KPMG adviser.
Information is current to June 12, 2023. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500
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