Thank you for the question.
I'm happy to provide some general comments on the proposed amendment on the collection of tax debts. There's an existing section in the Income Tax Act—section 160—that is intended to prevent somebody who owes taxes from moving their assets to a non-arm's-length person to avoid having to pay the tax debts they owe. Tax planning that seeks to frustrate that rule and prevent its application has arisen, with the ultimate objective being that people or corporations that owe taxes typically could move their assets through a series of transactions very carefully ordered and staged so that the assets were moved ultimately to another entity so that when it came time to pay the taxes, the corporation or the legal entity with the tax liability had nothing left to pay and the Canada Revenue Agency was frustrated in its attempts to collect the taxes. This sort of tax planning is highly aggressive, to say the least, owing taxes and then moving your assets away so that the Crown can't collect.
The budget 2021 proposal would attempt to help fix the wording of section 160 so that it can't be avoided and so that it achieves its initial policy intent in order to prevent this type of planning and to ensure that everybody pays the taxes that they owe. It improves upon an existing mechanism in the Income Tax Act to help improve fairness.