Tax Alert – Canada

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ETA holding corporation proposals: update

No. 24, 27 May 2019

On 17 May 2019, the Department of Finance (Finance) released a package of draft legislative proposals and explanatory notes relating to the holding corporation rules contained in section 186 of the Excise Tax Act (ETA). These proposals would extend the application of the rules to include holding partnerships and trusts. Finance indicated that it had considered submissions from industry stakeholders and other interested parties relating to the original legislative proposals released on 27 July 2018, as well as a consultation paper released on the same day.

In addition to the proposed changes to the holding corporation rules, Finance has released draft amendments to the ETA that would:

  • Extend the application of the drop shipment rules to commercially interchangeable or fungible goods
  • Treat virtual currency as a financial instrument for GST/HST purposes
  • Expand the definition of a freight transportation service so that zero-rated international freight transportation services would include international driving services

Interested parties are invited to provide comments on these legislative proposals by 17June2019.

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