Jim Flaherty, Canadian Minister of Finance, has proposed changes to the Income
Tax Act for Canadian businesses with foreign affiliates and those that report
earnings in a foreign currency.
"Our government is committed to creating a corporate tax system that is
both fair and internationally competitive," Flaherty stated on Friday.
"The proposals I am announcing today will improve the tax system and will
assist Canadian businesses in complying with the tax law."
Bill C-28, the second Budget 2007 implementation bill, provided tax relief
for Canadian businesses, including the corporate income tax rate reductions
announced in the 2007 Economic Statement. In addition, the bill, which received
Royal Assent on 14th December, 2007, implemented a number of amendments to the
Income Tax Act relating to foreign affiliates.
Included in the bill were provisions which allow taxpayers to elect retroactive
application of some of these foreign affiliate amendments. However, in response
to concerns that the deadline for filing these elections is too tight—for
example, a taxpayer with a 31st December 2007 year-end must file these elections
by 30th June, 2008—the government is proposing to extend the filing deadline
for these elections by 18 months.
Bill C-28 also included amendments to the Act that implemented the Budget 2006
proposal to introduce functional currency tax reporting rules. In response to
representations from stakeholders concerning the amended rules, the government
is proposing several technical revisions. These include: extending the deadline
to elect functional currency tax reporting to 31st October, 2008; amending the
definition of "functional currency" to address concerns about its
practical application to the situations of certain taxpayers; and introducing
symmetry in foreign exchange rate calculations used in the reporting of assets
and debt obligations.
Flaherty indicated that the government will introduce legislation at an early
opportunity to implement these proposed technical changes to the Income Tax
Act.