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Bill C-27

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SUMMARY

These amendments to the Income Tax Act implement measures released for public consultation on August 30, 1993. Most of the amendments are of a technical nature and many had been announced earlier. These were:

1. Draft amendments on qualified investments for RRSPs, released on February 4, 1993.

2. Draft legislation relating to the capital tax on life insurance companies, released on February 19, 1993.

3. Draft legislation relating to the simplification of the income tax treatment of automobile operating cost benefits, released on March 30, 1993.

4. Notice of Ways and Means Motion relating to cross-border purchase butterfly transactions, tabled on May 4, 1993.

5. Changes to withholding tax rules on securities lending arrangements, released on May 28, 1993.

Other measures of greater significance are:

6. RRSPs on death: provides that after an individual dies, the individual's legal representative can pay an RRSP premium on behalf of the individual for the benefit of a surviving spouse up to 60 days after the end of the year of death.

7. Loss of source of income: provides a deduction for interest on funds borrowed by a taxpayer to earn business income or certain types of investment income where the interest would otherwise be rendered non-deductible because the business assets or investment property financed by the borrowing have been disposed of at a loss or have become valueless.

8. Changes in residence: rules that apply to all individuals and corporations moving into or leaving Canada. The overall result is to ensure that Canada recognizes only income, or losses, either earned in Canada or attributable to the time the taxpayer resided in Canada.

9. SR&ED expenditures: this measure was introduced in the February 22, 1994 budget and requires taxpayers to identify scientific research and experimental development expenditures as such in order to qualify for the investment tax credit.