Joint Committee, "August 15, 2025 Legislative Proposals", Submission of the Joint Committee dated 15 September 2025

Summary Under
Tax Topics - Income Tax Act - Section 149 - Subsection 149(13)

NPO reporting

  • Regarding proposed s. 149(13), it is recommended that a de minimis test be introduced so that small nonprofit organizations are not...

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Summary Under
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Exempt Interest And Financing Expenses - Paragraph (b) - Subparagraph (b)(iii)

Expansion of exemption for purpose-built residential rentals

  • The exclusion in the definition of exempt interest financing expense for borrowings...

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Summary Under
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(20)

Revocation of election

  • The election under s. 18.2(20) to cause the income of a Canadian regulated energy utility business to be forever excluded...

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Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(4.7)

Backdating an Effective Date to December 31, 2023

The proposed amendments to accommodate foreign jurisdictions that have implemented a domestic...

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Summary Under
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - D - Paragraph D(b)

Paragraph E(a) double deduction for loss carryforwards

  • Paragraph E(a) of the ATI definition should be deleted to prevent duplication, given the...

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Summary Under
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(4) - Paragraph 85.1(4)(a) - Subparagraph 85.1(4)(a)(i)

Property Carve-Outs

  • S. 85.1(4) excludes rollover treatment for a drop-down described in s. 85.1(3) where there is a “relevant disposition” as...

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Summary Under
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(4) - Paragraph 85.1(4)(a) - Subparagraph 85.1(4)(a)(i) - Clause 85.1(4)(a)(i)(B)

Exception for s. 17 CFAs

  • S. 85.1(4)(a)(ii)(B) describes one of the “bad” transferees for purposes of what is a relevant disposition, namely,...

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