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Finance committee Clause 83 is consequential changes for the advanced life deferred annuity measures relating to disclosure requirements in respect of an ALDA.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Currently the tax rules provide for an accelerated deduction in respect of certain zero-emission vehicle properties. These amendments would extend the class of vehicles eligible for the enhanced zero-emission vehicle deduction. It would include things like off-road vehicles and it would extend the capital cost allowance or tax depreciation deduction.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Well, there are requirements that need to be met. One of the existing prohibitions was that they had to be driven on a road. I don't think there are distinctions made between types. In terms of the specific technologies and types of vehicles, is my colleague, Maude Lavoie, able to join in, or maybe Dave Beaulne, who worked on the file?
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee That's right.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee No. I would be happy to take up the discussion.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Clause 63 is another consequential amendment that comes under the advanced life deferred annuity rules, the ALDA rules. It relates to extended meanings of “spouse” and “former spouse” that can apply for the purposes of the ALDA rules. It extends the rules in subsection 252(3) to be available for the ALDA rules.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Clause 64 amends section 260 of the act, which involves the rules dealing with securities lending arrangements. I've already discussed this measure in the context of the part XIII withholding tax rules in section 212 of the Income Tax Act, and this provides the other portion of the securities lending arrangement rules that exist in section 260 of the act, which is where the securities lending arrangement rules work, so it relates to that measure.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Thank you. Perhaps a larger threshold is that it ends part 1 of the act, so I would turn things over to my colleague Pierre Mercille, who will be able to speak to part 2. Thank you.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Clause 61 amends section 248 of the Income Tax Act. Section 248 contains the definitions that are relevant generally for the purposes of the Income Tax Act, so there are several measures that are reflected in clause 61. I'll go through each of them. The first measure relates to the definition of a “derivative forward arrangement”.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Yes, there are certainly anti-avoidance rules, including the general anti-avoidance rule.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee That's right.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee I'd probably answer that in two ways. One is that not every GAAR case applies in the way that the Crown hopes, so sometimes it's necessary to make these amendments when the GAAR is found not to apply. That also happens when in a lot of cases when the government spots a new type of planning that's being used to exploit the current rules.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Clause 62 provides a consequential amendment related to the changes for the basic personal amount.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Clause 59 is a consequential amendment related to the electronic delivery of requirements for information.
May 27th, 2021Committee meeting
Trevor McGowan
Finance committee Clause 60 provides the more significant amendment relating to transfer pricing. As we have discussed, transfer pricing refers to the prices charged in cross-border transactions between non-arm's-length parties. When those rules apply, they essentially can reprice or recharacterize transactions to be in accordance with arm's-length terms and conditions.
May 27th, 2021Committee meeting
Trevor McGowan