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13 August 2018

Canada's Department of Finance releases draft amendments and proposals for ETA section 186 holding corporation rules

The Department of Finance released a package of draft legislative proposals and explanatory notes on July 27, relating to a number of measures announced in the 2018 federal budget, including draft amendments to the holding corporation rules contained in section 186 of the Excise Tax Act (ETA or the Act). These amendments would broaden the "commercial operating corporation property test" that an operating corporation must meet for the parent to benefit from the holding corporation rules and also specify certain circumstances under which the parent can claim an ITC.

A Tax Alert prepared by Ernst & Young Canada, and attached below, provides additional details.

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Document ID: 2018-1628

 

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