Refine by MP, party, committee, province, or result type.
Finance committee Yes.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee That is part of the logic behind it. But you're correct in your comment that there is no distinction made among taxpayers. It would be a little difficult for the Canada Revenue Agency to try to do that.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee Correct.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee That's correct, although I suspect in those circumstances the taxpayer can control where the debt or where the unpaid tax is.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee Yes.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee Yes, some would argue that the risk profile of the two debtors is different.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee The Americans are already in that kind of a position, and most of our treaty partners are in that sort of a position, so what we're really doing is catching up with many other countries.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee Certainly. Historically, “taxable Canadian property” has included items such as real property located in Canada, timber limits, and resource properties in Canada. It has also included things like shares of private companies, so shares of a privately owned corporation would be considered to be taxable Canadian property.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee Let's say, for example, that a U.S. multinational has a Canadian subsidiary and seeks to sell that subsidiary to a purchaser. Prior to this change those shares would have been taxable Canadian property. The U.S. multinational likely would not have been taxable on that sale because it would have been protected from Canadian tax under the treaty with the U.S., but it still would have been required to go to Revenue Canada to get a clearance certificate in advance of the sale of those shares.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee Likely not. Historically, shares of publicly traded companies were not taxable Canadian property. The exception was a circumstance whereby the non-resident held 25% or more of the shares of a class of that company. But typically for the retail-level investor, for most investors in publicly listed shares, they were not taxable Canadian property even before these changes.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee Real estate is taxable Canadian property and will continue to be.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee It'll be relevant for most small businesses because for the vast majority the shares of those companies would be taxable Canadian property under the current rules and will not be under the new rules. The exception is where the company derives its value principally from real property or has done so within the previous 60 months.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee There is a differential on the rates, yes. There has been a differential in the past. That differential will now be greater. It was 2% prior to this change; it will be 4% difference now.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee As I say, different arguments can be made. The argument has been made that the risk profile is different between different debtors, between the government and.... If, for example, the corporation were to go out and borrow in the public markets, it would pay a higher rate than would the government.
April 22nd, 2010Committee meeting
Tim Wach
Finance committee Then there would be a 2% difference.
April 22nd, 2010Committee meeting
Tim Wach