Estate freeze: A tax planning tool for business owners
Tax alertBusiness owners and investors can use tools like estate freezes to navigate market volatility, boosting security and certainty in uncertain economies.
27 Jun 20226 min read

Relief for certain late-filed wage and rent subsidy claims
Bill C-19 includes legislation that provides the CRA with the discretion to accept late-filed wage and rent subsidy claims on a case-by-case basis in exceptional circumstances. This legislation applies retroactively to April 11, 2020, which was the end date of the first claim period for the Canada Emergency Wage Subsidy (CEWS).
The process for making a request—and the types of circumstances the CRA will consider as being exceptional—hasn’t been announced, however this is welcome news for taxpayers that may qualify.
Immediate expensing rules
Bill C-19 includes legislation to implement the immediate expensing rules proposed in Budget 2021. This allows Canadian-Controlled Private Corporations (CCPCs) to immediately write-off up to $1.5 million of certain eligible capital property purchased on or after April 19, 2021 and becomes available for use before January 1, 2024. This tax incentive is also available to Canadian resident sole proprietors and certain eligible partnerships, but only for purchases on or after January 1, 2022.
Eligible capital property includes most property subject to the capital cost allowance rules, but excludes classes 1 to 6 (i.e., buildings), 14.1, 17, 47, 49 and 51, which are generally long-lived assets.
The $1.5 million limit must be shared by associated parties and is prorated for short taxation years. Any unused portion of the limit cannot be carried forward. See our Budget 2021 summary for more details.
Tax reduction for zero-emission technology manufacturers
As proposed in Budget 2021, Bill C-19 includes a temporary reduction in the federal corporate tax rate for eligible zero-emission technology manufacturers as follows:
To be eligible, at least 10 per cent of the corporation’s gross revenue from all active businesses carried on in Canada must be derived from qualifying zero-emission technology manufacturing or processing activities. Also, the reduce rates only apply to the corporation’s zero-emission technology profits.
The reduced tax rates apply to taxation years that begin after 2021 and will be gradually phased out starting with taxation years that begin in 2029 and fully phased out for taxation years that begin after 2031.
Luxury tax
Another important tax measure in Bill C-19 is the new luxury tax. Originally proposed in Budget 2021, new cars and personal aircraft worth over $100,000 and new boats or yachts priced over $250,000 will be subject to an additional luxury sales tax. The tax is calculated as the lesser of:
The luxury tax will come into force on September 1, 2022. See our tax alert article on luxury tax for more details.
Charitable partnership
As introduced in Budget 2022, restrictions are now eased on certain grants made by charities to third-party organizations. Previously, registered charities were only permitted to use their resources for their own charitable activities or for gifts to other qualified donees. Legislative amendments in Bill C-19 extend the scope of permissible disbursements to include certain non-qualified donees if they further the charity’s purposes. The grantor charity is required to meet several accountability requirements such as pre-grant screening, written agreements, ongoing monitoring, and reviewing and approving the final report of the grantee. This measure applies to disbursements made on or after June 23, 2022.
Other tax measures
If you need help navigating these tax measures or have any questions, our advisors are here to help you—reach out to us here.
Disclaimer
The information contained herein is general in nature and is based on proposals that are subject to change. It is not, and should not be construed as, accounting, legal, or tax advice or an opinion provided by Doane Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, specific circumstances or needs and may require consideration of other factors not described herein.
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