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Top Tour Operators and Travel Agencies in Canada 2024/2025

Top Tour Operators and Travel Agencies in Canada. Below you will find 19 of the best tour operators and travel agencies in Canada offering in total 135 tours and holidays through-out Canada. Combined they have received 68 customer reviews and an average rating of 5 out of 5 stars. The top tour activities offered in Canada are: Wildlife, landscapes and nature, Adventure and sport & Boat tours, water sports and marine wildlife.

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19 Tour Operators in Canada with 68 Reviews

Intrepid Travel

• Address 380 Lonsdale Street, Melbourne, Australia
• Response Rate 90%
• Response Time 2 hours

• Best-in-Class Top 5% of companies
• Excellent Service Top 10% of companies
• Superior Service Top 15% of companies

Exodus Travels

• Address Grange Mills, Weir Road, London, England
• Response Rate 85%
• Response Time 1 hour

• Address 33 Kern Road, Toronto, Canada
• Response Rate 88%
• Response Time 3 hours

G Adventures

• Address G Adventures Ltd, 60 Bastwick Street, London, England

Quark Expeditions

• Address 3131 Elliot Avenue, Suite 250 Seattle, WA 98121, Seattle, USA
• Response Rate 79%

• Address 109 Power Road, Chiswick, London, England
• Response Rate 81%

• Address Nelson House, 55-59 Victoria Rd, Farnborough, England
• Response Rate 96%

Luxury Gold

• Response Rate 60%

New World Wine Tours

• Address 100 Lower Ossington Ave, Toronto, Canada
• Response Rate 40%

Insight Vacations

• Response Rate 86%

Scenic Luxury Cruises and Tours

• Address 15/56 Pitt St, Sydney, Australia
• Response Rate 74%

Indus Travels

• Address 233, 11951 Hammersmith Way, Richmond, Canada
• Response Rate 97%

Collette Tours

• Address 162 Middle Street, Pawtucket, Rhode Island, USA

• Address 2461 FM 778, Mineola, USA
• Response Rate 95%

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Experience Canada with Landsby

Landsby creates unique and immersive experiences that not only provide travellers with purposeful and enriching trips but aim to positively impact the communities being explored. We are supporting and rebuilding Canada’s tourism sector through innovative collaborations, storytelling, and a focus on Indigenous and Regenerative travel. 

• We are an award-winning Canadian travel company, based in Toronto
• We are Canada's first and only Regenerative Travel Agency of Change
• We are the First Canadian Travel Company to Invest in a Smart Forest™
• We offer singular experiences sourced from the best Canadian suppliers, including the largest collection of Canadian Signature Experiences
• We are committed to growing Canada's Indigenous tourism sector and have signed ITAC's 2030 Vision Pledge
• We are Rocky Mountaineer and VIA Rail Experts

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Go Kanada Travel is a wholly Canadian-owned corporation and one of Canada’s leading incoming-travel operators, providing a comprehensive range of services and products for local and international travelers, groups and industry partners worldwide, including Travel Agencies, tour operators and event organisers.

We are a fast expanding, dynamic company with focus on the best travel experience for every budget. True to our founding principles, the client’s experience should always come first.

We are based in Western Canada, with affiliates in most major Canadian cities.

Experience you can count (on)!

2,564,000 Bus kilometers

1,910,000 Plane kilometers

54,680 Happy Travellers

5,440 Hotel nights

Our winning team of travel-industry professionals shares over 2.4 million bus Kilometers, over 5,400 hotel nights and more than eighty years of experience between them. We know and love Canada from the wild Pacific to the stormy Atlantic, over the Rocky Mountains and the prairies, from Niagara Falls to the Arctic Circle, and we love sharing Canada’s beauty with you, the way friends and family would.

Our promise

“At Go Kanada Travel, we constantly strive to exceed the expectations of our customers and guests by welcoming them to Canada like family and by providing them with unforgettable experiences and memories.” Anja Geithner, CEO

Anja Geithner, CEO

Anja holds a bachelor’s degree in Tourism, is a certified travel agent and a certified tour director. Anja was born and raised in Germany and settled in Canada in 2004. She spent over 25 years showing travellers Canada as well as over 60 countries on 6 continents.

During the 2010 Winter Olympic Games, as member of the National Olympic Committee assistant team, Anja co-hosted the Austrian Olympians in Whistler, BC.

Anja’s experience, love for Canada, and passion for travel eventually culminated in her co-founding of Go Kanada Travel.

Anja lives with her family in Vancouver in British Columbia

Peter Wolf, GM

Following the call of the wild, Peter moved to Canada from Sydney, Australia, in 2007. Soon after being part of the Canadian 2010 Winter Olympic Games logistics and transportation team, he left the corporate world and devoted his time to sharing Canada’s beauty with travellers from around the world – over 20,000 to-date and counting.

Peter’s business background and his desire to offer the best travel experience led to him being the co-founder of Go Kanada Travel.

When not inspecting and exploring attractions and locations across Canada, Peter is busy coordinating the production of Go Kanada’s travel documentaries.

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Real Canada!

Thank you for this perfectly organized trip! We loved the truly Canadian experiences and the unique variety of accommodation. The location for the farewell dinner was a real surprise!

Jürgen & Christine G.

Whales, bears and moose

Whales, bears, moose, endless nature! We saw and experienced so much, but we also had the time to just pause and enjoy the moment. Thanks again for the great insider tips!

Andrea & Dieter M.

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The Best Canada Tour Companies To Discover Canada With!

Posted on Last updated: December 15, 2023

Categories Canada

Expert travel storyteller Jordan Adkins, founder of InspiredByMaps.com, brings a decade of adventures across 101 countries and 450+ UNESCO sites into rich, off-the-beaten-path narratives, melding ecological expertise with genuine, seasoned travel insights. His full bio can be found here.

Much of the magic of Canada lies in the fact that it’s the world’s second-biggest country by area but has a population of a mere 37 million. This means that vast expanse of its stunning landscape are unpopulated and unspoiled, and a dream to explore.

It’s hard to overstate the impact of nature here. Acres of deep-green, mysterious forest, soaring mountains, sparkling glaciers, vast expanses of glassy lakes and secluded beaches make up a diverse landscape that explorers and locals glory in.

See as much of it as you can. Go skiing in Whistler, scuba-diving off the Bruce Peninsula or white-water rafting along the South Nahanni River if you’re an adrenaline junkie.

If you want to set a more sedate pace, there are plenty of options for walks and hikes, as well as beach-bumming.

All this countryside means that Canada abounds in fresh produce. The seafood in British Colombia is sublime, while the local wines will surprise you.

The country doesn’t need much in the way of complex flavorings or techniques, because the raw materials it’s working with are so damn good. Simple, excellent dishes are the perfect accompaniment to the days spent outdoors.

Of course, while Canada is famous for its rural areas , its urban ones are not to be dismissed! Vancouver is one of those cities that has travelers looking up house prices after about a day here; Toronto has a diverse arts scene; Montreal maintains its delightfully French feel and Ottawa has stunning views and museums galore.

It’s a far more innovative country than endless jokes on American sitcoms would have you believe, that’s for sure!

So why take a tour in Canada? Surely it’s easy enough to travel around independently. Well, that’s certainly true, but there are hundreds of hidden gems here that you might not stumble across on your own.

These Canada tour companies have the knowledge and experience to help you see all the best things the country has to offer. Plus, you won’t have to spend 4 months before you travel frantically Googling ‘things to do in Canada’, which is always a win for us!

As well as the convenience and depth of experience, a tour is also a wonderful way to meet people. Seeing a new country is such a pleasure, and even more so when you’re in good company.

The Best Canada Tour Companies To Discover Canada With! 🇨🇦

Page Contents

Fresh Adventures

Trek america, out here travel.

If you’re trying to choose between several Canada tour companies, you can’t go wrong with a local one. Fresh Adventures is a Canadian tour company run and staffed by people who are passionate about this beautiful country.

Your guides are all locals and can take you to all the best spots and tell you all the best stories along the way. Wilderness and community are among their core values, and this shows in every aspect of the carefully considered tours.

The tours make the most of the great Canadian outdoors with lots of options for adrenaline-pumping activities, while the food on offer is locally sourced and deliciously fresh. They are also proud of not charging a single supplement resulting in over 50% of their guests being solo travellers.

This means you’re likely to have a sociable and friendly experience as you enjoy adventures in the wild.

Example Tour: British Columbia Ski Tour

Ski bunnies, take heed – this is your dream tour. If you lust after untouched, powdery snow, the craggy mountain peaks watching over you as you swoosh down the slopes, British Columbia awaits. This 9-day tour takes you to some of the finest slopes in the country, from the astoundingly steep slopes of ‘Mania’ and ‘’Discipline’ in Revelstoke to the panoramic views from Kicking Horse.

After skiing till you drop, you can soak in the hot springs at Lussier and Ainsworth to soothe those tired muscles. Three nights in the town of Nelson offers that idyllic après ski life, with over 80 bars and restaurants crammed into this little town.

A guided ski tour means you won’t miss out on anything as your local guide takes you to slopes and attractions off the beaten path. You’ll finish tired, happy, and totally in love with Canada!

Approx. price per day: £170.

From its beginnings in Switzerland over 80 years ago, Cosmos has grown into a global company that still manages to maintain its personal touch.

The company’s passion lies in showing travelers the best of the world, and in minimizing the hassle along the way. They love travel, and they want the rest of us to love it too. You definitely travel in comfort, with all hotels 3-star or more and first-class coaches, but these little luxuries aren’t overpriced. In fact, we find their tours pleasingly good value.

The professional ‘Tour Directors’ in each destination are a great asset. They can tell you more about the places you visit, offer advice on where to eat and explore, and help with any issues that come up. Cosmos also allows for flexibility, so there are plenty of optional excursions that you can choose from to design a holiday that perfectly fits your travel style.

In a country as huge as Canada, it definitely helps to have someone else doing all the planning for you!

Example Tour: Ontario and French Canada with Ocean Train To Halifax

This fantastic tour is 12 days taking in the cultural side of Canada, from Ontario through Toronto, Canada’s biggest city, and Halifax with six other destinations along the way.

It’s a pleasantly sedate trip that still feels that you have seen a good portion of the beautiful scenery and engaging cities in this part of the country. It’s fascinating to see aspects of French America such as the Basilica of Notre Dame and Place Royale square in Quebec.

The overnight Ocean Train from Montreal to Halifax is a delightfully different way to travel, and feels luxurious as you enjoy the views of Nova Scotia from your private sleeper car. It’s not only cities, either; you can also take a thrilling boat cruise to Niagara Falls and go sightseeing through the islands in St Lawrence Islands National Park.

In fact, the itinerary is the perfect mix of a lively city and spectacular scenery, and will certainly give you a taste for Canada.

Approx. price per day: £140.

A Topdeck tour is a trip that’s packed full of adventure, experience, and fun. Their age range is 18 to 39 as they dedicate themselves to inspiring younger people to travel. Exploration and freedom are at the heart of what they do. It started back in 1973 with a bunch of friends on a bus to Morocco and those are the vibes they endeavor to keep creating.

Their trips are always pretty full-on, with lots of destinations and lots of fun in the evenings, so don’t expect a gentle pace! Having said that, the team here knows that young adventurers want the opportunity to be independent, so there are lots of opt-in activities and the chance to explore yourself.

Fantastic tour guides and drivers make the experience something special, and friendly fellow guests (over 50% solo travelers) create a sociable atmosphere.

Example Tour: Canadian Rockies

This 10-day adventure tour starts and finishes in Vancouver, taking you on a round trip through the glories of the Rocky Mountains. You’ll see the very best Canadian scenery in some of its finest National Parks, including Yoho, Banff and, of course, Whistler. We love that things kick off with wine tasting in Kelowna and a group dinner to get to know fellow travellers. After this, you’ll all be firm friends.

As you explore these stunning National Parks, you have options for add-ons like white-water rafting, ziplining and heli-tours. Entry to hot springs, the Athabasca Glacier tour, and bike hire is all included to help you enjoy the experience to the max.

You’ll find that there’s a lot more to Whistler than just skiing as you walk through the forests and explore the cafes and boutiques. It’s a tour for true adventurers who love to be outdoors.

Approx. price per day: £151.

This North American company is the only one offering small group (10 – 12 people) tours for the 18 to 38 age group, and boy, do they do it well! It’s been operating since 1972 so they’ve got plenty of experience in creating fun, adventurous and authentic tours that take people off the beaten path. Local guides and knowledge accumulated over 40 years mean that they know all the hidden gems and secret spots in an area.

We obviously think that travel is for everyone, but there’s also something nice about knowing that everyone in your tour group is going to be a similar age to you. It means that you’re likely to want to do similar things and be able to connect over shared experiences.

Even if you’re travelling alone, you’ll find you soon are part of a tight-knit group making wonderful memories.

Example Tour: Mountie

11 days of adventure in the rugged scenery of British Columbia and Alberta? Heart-stoppingly beautiful views, glassy lakes and walking through the cleanest air you can imagine? Sign us up now! This small group tour takes you from Vancouver to Calgary through some of the best wilderness Canada has to offer – Wells Gray Provincial Park, Jasper, Banff and Yoho National Parks, and Icefields Parkway.

Aside from gazing in awe at the vistas around you, there is tons for you to do on this exhilarating trip. Hike through Well Gray to see gorgeous Helmcken Falls, spot Grizzlies in Jasper, trek the Wapta Falls and Emerald Lake Loop and opt for some white-water rafting if you want to get your heart rate up. Lake Louise is another particularly beautiful spot for a stroll and a cup of tea.

An expert and friendly guide, plus fellow travellers of your age make the experience even more special.

Approx. price per day: £122.

This is another local Canada tour company that wants to give visitors the best possible experience in their native land. They specialise in Canadian road trips with a large helping of adventure for ages 18 to 39. A very popular tour is their ‘Big One’ – 26 days of gorgeous scenery and fun in Central and Eastern Canada. If you have the time, it’s well worth it. Their other tours are of equally high quality, of course.

They build in a lot of flexibility and, unusually, schedule 2 or 3 days in each destination so you have a lot of time to explore and experience these areas. This slightly more chilled out pace makes the trip really special. You have time to get to know other travellers over a beer or a coffee, rather than dashing from place to place, and there are tons of activities.

It’s got the freedom of an independent trip, but these road trips definitely aren’t things you could do yourself. Their expertise and love for the country shines through in every aspect of their itineraries.

Example Tour: Winter Wild – Adventure Canada

Pack your thermals and woollies, it’s time for 12 days’ adventure in snow-blanketed Canada. It’s an incredibly beautiful time to see the country, when the snow and ice makes everything sparkle and brings a sense of peace and calm to the wilderness. This tour makes the most of this with lots of winter activities like snowmobiling, tobogganing, skating, skiing and (our favourite!) hot-tubbing!

You’ll explore Ontario and Quebec, taking in places like craggy Algonquin Park, the winter wonderland at St Lawrence River, picturesque Quebec City , and sophisticated Montreal . This Winter Wild tour can sometimes encompass festivals like IglooFest (the world’s coldest outdoor music festival) or Winter Carnival in Quebec City – if you want a chance to see these, get in touch with Out Here.

And remember: there’s no such thing as bad weather, only bad clothes! So, try everything once and enjoy the magic of Canada in the winter.

Approx. price per day: £59 – not including accommodation.

Best Canada Luxury Tour Companies

Search 46 Canada Luxury tour operators and travel companies, with 40 reviews.

G Adventures

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Destination America

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Canada Luxury Reviews & Ratings

Very good trip.

Very good trip. One comment though- as we were all non Canadians , I felt G Adventures could have supplied us with more information on the social and economic histor...

Wonderful trip, knowledgeable CEO, great people, fabulous time

Wonderful trip, knowledgeable CEO, great people, fabulous time. I loved it!

Breathtaking

Breathtaking! I had the time of my life. Beautiful scenery, amazing activities, incredible adventures,... I'll cherish every moment this trip for a long time to come...

The awesome scenery just went on and on and on

The awesome scenery just went on and on and on. Every day there where more amazing things to experience. Bears, eagles, Orka's, walking on a glacier and bathing in t...

My first long haul holiday so a bit apprehensive, no need, Excellent itinery,stunning scenery,impecably well organised

My first long haul holiday so a bit apprehensive, no need, Excellent itiner...

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Welcome to Robin Hood Tours, your one stop travel shop!

We are a proud Canadian owned and operated company.  Our specialty is guided day and multi day tours which highlight fabulous local attractions, theatres, restaurants, and more aboard our deluxe motorcoaches.

We also provide complete, worry - free travel arrangements for air, cruise, rail, all inclusive vacations, and bucket list trips as well as comprehensive travel insurance. 

We welcome groups of all sizes and will customize an itinerary designed to meet your group’s dreams.

Robin Hood Tours has implemented the new safety measures for travelers that the @ WTTC has recognized and approved through the #safe travels stamp.

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TICO#: 2065968/50025714

Operated by Cherrey Bus Lines, and owned by the Badder Group of Companies Badder Bus

Welcome to CATO

We represent the interests and advocate on behalf of canadian tour operators.

The Canadian Association of Tour Operators (CATO) is a non-profit organization, consisting of highly respected tour operators from across Canada as well as supporting members.

CATO’s primary role is to inform government and other stakeholders of issues important to its members as well as advocate on their behalf.

What We Stand For

And how we can help you.

CATO is driven by a passionate group of volunteers who donate their time and ideas to advocate for an industry that is diverse, complex and has a foothold in virtually every community across Canada.

CATO’s members include organizations offering tour programs and travel packages originating from Canada to international destinations as well as inbound to Canada, intra-Canada and trans-border.

Join CATO today.

Our membership compromises some of the biggest travel brands in Canada, smaller long standing business, niche companies, aspiring start-ups, supporting members and anyone in between. Our door is open to any tour operator with a passion for our industry.

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Ontario Tour Companies

Looking for an unforgettable Ontario tour? Book a fully-organized trip with the best tour companies in Ontario and let the tour operator take care of everything for you. Check out the tour details and read 25452 reviews from our customers to help you choose the perfect tour for you.

List of Ontario travel companies & tour operators with 25452 reviews

Voyageur Quest

• Excellent - 7 reviews for Ontario tours

The division of the children on the canoes worked very well. Thanks to the division of the 2Gruppen our group as a family could experience the trip at their own pace (children). Will (guide) was very experienced and competent in canoeing and camping and showed us everything wonderfully. He was also always accommodating and very personable. Thank you so much for taking our youngest daughter in his canoe (9 year old)! The meals were very tasty every time! Thanks to the organization of the trip we were able to combine action and enjoyment. The children and we as parents enjoyed the trip very much!

I had many firsts in this trip, first time canoeing, staying in cabin with strangers, first time in Algonquin, seeing the night sky. We had the A-team for sure, Nicolene, Baris and Reese (I hope I did not mess the spellings, my apology)it would not have been a great experience without you. Forever grateful.

• Excellent - 1,892 reviews for Ontario tours

Optional excursions were reasonably priced. Suggest you put together other places in each city as a walking guide or short taxi or uber ride. Example access to close by museums open late and could walk to from hotel. Free time activities and what they are and where located is helpful.tour guide can offer to accompany a group interested to explore more during free leisure tome.Provide more detail info about the logistics of site visits. Niagara falls..suggest more water proof gear clothing and shoe types etc. Terrain to expect when visiting certain sites and possible alternatives.climbing and how difficult-easy or more strenuous or advanced climbing activity. Overall, small groups so much better than filling up bus. Thank you for giving single travelers their own bus space. Would love to watch more travel videos on longer driving distances.

• Excellent - 19,645 reviews for Ontario tours

Tour was as advertised with some good options. The guide ensured the group was on time and the driver was excellent. We appreciated the chance to use the Cosmos hotels both before and after the tour.

Great knowledge guide, excellent and competent coach driver, beautiful and well located accommodation. Also like the rotation of seats during the tour. So no complaints here.

Europamundo

• Good - 2,998 reviews for Ontario tours
• This operator has no Ontario reviews

Insight Vacations

• Excellent - 631 reviews for Ontario tours

Best Single Travel

• Good - 7 reviews for Ontario tours

Tour items were changed without notice

Global Conquest

• Excellent - 2 reviews for Ontario tours

Omega Tours

• Good - 169 reviews for Ontario tours

• Excellent - 75 reviews for Ontario tours

Luxury Gold

• Excellent - 26 reviews for Ontario tours

The cities we visited were beautiful, I just wish that the time on the bus was less. Change the dinner place in Ottawa, not up to your standards! We did not enjoy the canal cruise, it was too long, boring, and would have preferred that time to see sights. Ben was excellent! His historic knowledge, stories, and sense of humor made traveling most enjoyable. Our bus driver was such a gentleman and so accommodating. His driving was superb, I never felt unsafe. Most enjoyable was Niagara Falls and Quebec. Wish we had more time in Quebec less time in Montreal.

What a spectacular part of Canada the eastern side is and what a way it was to experience it by travelling with Luxury Gold. From Max our knowledgeable and ever attentive Travelling Concierge to the luxury coach that we travelled on to the Fairmont included properties and the meals were fantastic too. I found this Luxury Gold trip to be the right balance between included experiences and time at leisure to add a few things that really interested me (including some shopping). Trip highlights included the picturesque Fairmont Château Frontenac where we stayed in Quebec and enjoyed a tour with a Local Expert of the incredible property located right on the Saint Lawrence River. From Toronto it was magical to go to Niagara Falls and see icebergs in the lake and we even had snow flakes fall. Looking forward to my next trip with Luxury Gold as I enjoyed this trip.

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2024 Federal Budget analysis

On April 16, 2024, the Deputy Prime Minister and Minister of Finance, Chrystia Freeland, presented the government’s budget. The budget:

• increases the capital gains inclusion rate from 1/2 to 2/3, effective June 25, 2024 (up to $250,000 of annual gains for individuals will continue to benefit from the 1/2 inclusion rate)
• raises the lifetime capital gains exemption to $1.25 million and introduces a new 1/3 inclusion rate for up to $2 million of certain capital gains realized by entrepreneurs
• confirms previously announced alternative minimum tax proposals effective January 1, 2024, but softens the impact of these proposals on charitable donations
• provides design and implementation details for the clean electricity investment tax credit
• introduces accelerated capital cost allowance (CCA) for, and relief from interest deductibility limitations for debt incurred to fund the construction of, certain purpose-built rental housing
• provides immediate expensing for the cost of certain patents and computer equipment and software
• gives the Canada Revenue Agency (CRA) additional information gathering powers

This Tax Insights discusses these and other tax initiatives proposed in the budget.

Tax measures

Capital gains inclusion rate.

• Lifetime Capital Gains Exemption

Canadian Entrepreneurs’ Incentive

• Alternative Minimum Tax

Employee Ownership Trust Tax Exemption

Volunteer firefighters tax credit and search and rescue volunteers tax credit, mineral exploration tax credit for flow-through share investors.

• Canada Child Benefit

Disability Supports Deduction

Charities and qualified donees.

• Home Buyers’ Plan

Qualified Investments for Registered Plans

Deduction for tradespeople’s travel expenses, indigenous child and family services settlement, clean electricity investment tax credit, ev supply chain investment tax credit, clean technology manufacturing investment tax credit.

• Accelerated Capital Cost Allowance

Interest Deductions and Purpose-Built Rental Housing

Taxing vacant lands to incentivize construction, confronting the financialization of housing, halal mortgages, non-compliance with information requests, synthetic equity arrangements, mutual fund corporations, canada carbon rebate for small business, avoidance of tax debts, reportable and notifiable transactions penalty, manipulation of bankrupt status.

• Scientific Research and Experimental Development

International

Crypto-asset reporting, withholding for non-resident service providers, international tax reform.

• Extending GST Relief to Student Residences

GST/HST on Face Masks and Face Shields

Previously announced, personal tax measures.

The budget proposes to increase the capital gains inclusion rate from 1/2 to:

• 2/3 for dispositions after June 24, 2024 for corporations and trusts, and
• 2/3 for the portion of capital gains realized after June 24, 2024 in excess of an annual $250,000 threshold for individuals

The $250,000 annual threshold would apply to capital gains realized by an individual, either directly or indirectly via a partnership or trust, net of:

• current year capital losses
• capital losses of other years applied to reduce current year capital gains, and
• capital gains in respect of which the Lifetime Capital Gains Exemption (LCGE), the proposed Employee Ownership Trust Exemption or the proposed Canadian Entrepreneurs’ Incentive is claimed

As a result, the following rates will apply to capital gains earned by individuals in excess of the $250,000 threshold who are subject to the top marginal income tax rate (i.e. on taxable income exceeding: $355,845 in Alberta, $252,752 in British Columbia, $1,103,478 in Newfoundland and Labrador, $500,000 in the Yukon and $246,752 in all other jurisdictions).

The budget also proposes to decrease the stock option deduction to 1/3 to align with the new capital gains inclusion rate.  Individuals would continue to benefit from a deduction of 1/2 of the taxable benefit up to a combined $250,000 for both employee stock options and capital gains.

The inclusion rate for net capital losses carried forward and applied against capital gains will be adjusted to reflect the inclusion rate of the capital gains being offset.   

Transitional rules will apply to taxation years that begin before June 25, 2024 and end after June 24, 2024 such that capital gains realized before June 25, 2024 would be subject to the 1/2 inclusion rate and capital gains realized after June 24, 2024 (net of any losses) would be subject to a 2/3 inclusion rate. The $250,000 threshold will not be prorated for individuals in 2024 and will apply only against capital gains incurred after June 24, 2024.

Additional details will be provided in the coming months.   

Earning capital gains through a Canadian-controlled private corporation (CCPC)

In most jurisdictions, the increase in the capital gains inclusion rate makes it less attractive for individuals to earn capital gains in excess of $250,000 through a CCPC instead of directly. The  Appendix shows the resulting income tax deferral (prepayment) and the tax cost for an individual who realizes capital gains in excess of $250,000 and pays tax at the top tax rate.

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Lifetime Capital Gains Exemption (LCGE)

The budget proposes to increase the LCGE on eligible capital gains from $1,016,836 to $1,250,000 for dispositions that occur after June 24, 2024. The indexing of the LCGE to inflation will resume in 2026.

The budget introduces the Canadian Entrepreneurs’ Incentive, which will reduce the taxes on capital gains from the disposition of shares by eligible individuals which meet the following conditions:

• at the time of the sale the share was a share of a small business corporation owned directly by an individual
• used principally in an active business carried on primarily in Canada by the CCPC or a related corporation
• certain shares or debts of connected corporations, or
• a combination of these assets
• the individual was a founding investor and the individual held the share for a period of five years prior to the disposition
• at all times since the share subscription until the time immediately before the sale, the individual directly owned shares with a fair market value (FMV) of more than 10% of the FMV of all of the issued and outstanding shares of the corporation and shares entitling the individual to more than 10% of the votes
• throughout the five year period before the disposition the individual was actively engaged in a regular, continuous and substantial basis in the activities of the business
• the share does not represent a direct or indirect interest in a professional corporation, a corporation whose principal asset is the reputation or skill of one or more employees, or a corporation that carries on certain types of businesses including a business operating in the financial, insurance, real estate, food and accommodation, arts, recreation, or entertainment sector, or providing consulting or personal care services
• the share must have been obtained for fair market value consideration

The incentive would provide a capital gains inclusion rate of one half of the prevailing inclusion rate on up to $2 million in capital gains per individual during their lifetime. The $2 million limit will be phased in over 10 years by increments of $200,000 per year reaching $2 million by January 1, 2034.  

Applying the proposed 2/3 inclusion rate would result in an inclusion rate of 1/3 for qualifying dispositions.  This will apply in addition to the LCGE.

This measure would apply to dispositions that occur after December 31, 2024.

Alternative Minimum Tax (AMT)

The 2023 budget announced amendments to change the calculation of the AMT. Draft legislative proposals were released for consultation in the summer of 2023. (For more information, see our Tax Insights “ Proposed changes to the alternative minimum tax: How will it affect individuals and trusts ”.)

The budget proposes to revise the proposed charitable donation tax credit claim to allow individuals to claim 80% when calculating AMT (as opposed to the previously proposed 50%).

The budget also proposes additional amendments to the AMT proposals including:

• allowing deductions for the Guaranteed Income Supplement, social assistance and workers compensation payments
• fully exempting employee ownership trusts (EOTs) from the AMT, and
• allowing certain disallowed credits under the AMT to be eligible for the AMT carry-forward (i.e. the federal political contribution tax credit, investment tax credits (ITCs), and labour-sponsored funds tax credit)

The amendments would apply to taxation years that begin after December 31, 2023.

The budget also proposes certain technical amendments to the AMT legislative proposals to exempt certain trusts for the benefit of Indigenous groups.

The 2023 budget proposed tax rules to create EOTs. The 2023 Fall Economic Statement proposed to exempt $10 million of capital gains on the sale of a business to an EOT subject to certain conditions.

The budget introduces the conditions for this exemption. The exemption will be available to an individual (other than a trust) on the sale of a business to an EOT where the following conditions are met:

• the individual, a personal trust of which the individual is a beneficiary, or a partnership in which the individual is a member, disposes of shares of a corporation that is not a professional corporation
• the transaction is a qualifying business transfer (as defined in the proposed rules for EOTs) in which the trust acquiring the shares is not already an EOT or a similar trust with employee beneficiaries
• throughout the 24 months immediately prior to the qualifying business transfer, the transferred shares were exclusively owned by the individual claiming the exemption, a related person, or a partnership in which the individual is a member; and over 50% of the FMV of the corporation’s assets were used principally in an active business
• at any time prior to the qualifying business transfer, the individual (or their spouse or common-law partner) has been actively engaged in the qualifying business on a regular and continuous basis for a minimum period of 24 months
• immediately after the qualifying business transfer, at least 90% of the beneficiaries of the EOT are resident in Canada

Where multiple individuals dispose of shares to an EOT as part of a qualifying transfer and meet the conditions above, they may each claim an exemption, however the total exemption in respect of the sale cannot exceed $10 million. The individuals would have to agree on the allocation of the exemption.

If an EOT has a disqualifying event within 36 months of the transfer, the exemption claim will be retroactively denied. If this occurs more than 36 months after a transfer the EOT will be deemed to realize a capital gain equal to the total exempt capital gains. A disqualifying event would result where an EOT loses its status as an EOT or if less than 50% of the FMV of the qualifying business shares is attributable to assets used principally in an active business at the beginning of two consecutive years of the corporation.

The EOT, any corporation owned by the EOT that acquired the transferred shares, and the individual will need to elect to be jointly and severally, or solitarily liable for any tax payable by the individual as a result of an exemption being denied due to a disqualifying event occurring during the first 36 months.  

For the purposes of the AMT calculation the capital gain on the transfer would be subject to an inclusion rate of 30% (consistent with the inclusion rate for capital gains eligible for the LCGE).            

An individual’s normal reassessment period as it relates to this exemption is proposed to be extended by an additional three years.

The budget also proposes to expand qualifying business transfers to include the sale of shares to a workers cooperative corporation, provided it meets certain conditions.

These measures will apply to qualifying dispositions of shares that occur between January 1, 2024 through December 31, 2026.

The budget proposes to double the volunteer firefighters tax credit and the search and rescue volunteers tax credit to $6,000 for the 2024 and subsequent taxation years; this increases the maximum annual tax savings to $900.

The budget proposes to extend the eligibility for this credit for an additional year, so that it will apply to flow-through share agreements entered into before April 1, 2025.

Canada Child Benefit (CCB)

A CCB recipient is no longer eligible to claim the CCB in respect of a child in the month following the child’s death. The budget proposes to extend eligibility for the CCB to six months after the child’s death, provided the individual continued to be eligible for the CCB.

The budget proposes to extend the list of expenses recognized for the disability supports deduction.

It also provides that expenses for service animals, as defined under the medical expense tax credit (METC) rules, will be recognized under the disability supports deduction. The individual will choose whether to claim under the METC or the disability supports deduction.

A foreign charity may register as a qualified donee for a 24-month period where it received a gift from His Majesty in right of Canada and it is pursuing certain activities in the national interest of Canada.  The budget proposes to extend the eligibility of a foreign charity to be considered a qualified donee from 24 months to 36 months.  The foreign charity would also be required to submit an annual information return to the CRA that would be made publicly available. The extension will apply to foreign charities registered after April 16, 2024. The reporting requirements will apply to taxation years beginning after April 16, 2024.        

The budget also proposes to simplify the issuance of official donation receipts by removing certain requirements.

Home Buyers’ Plan (HBP)

To help first-time home buyers, the budget proposes to:

• increase, from $35,000 to $60,000, the amount that an eligible home buyer can withdraw from their Registered Retirement Savings Plan (RRSP) under the HBP, without subjecting the withdrawal to tax, to buy or build a qualifying home (i.e. a first home or a home for a specified disabled individual), effective for the 2024 and subsequent calendar years, for withdrawals made after April 16, 2024
• temporarily extend the repayment grace period by three years, to five years, under the HBP, so that eligible home buyers who withdraw from their RRSP between January 1, 2022 and December 31, 2025 will have up to five years before they need to start repayments to their RRSP

Registered plans (RRSPs, Registered Retirement Income Funds, Tax-Free Savings Accounts, Registered Education Savings Plans, Registered Disability Savings Plans, First Home Savings Accounts, and Deferred Profit Sharing Plans) can invest only in qualified investments for those plans. Qualified investments include mutual funds, publicly traded securities, government and corporate bonds and guaranteed investment certificates. Over the years the qualified investment rules have been expanded to include additional investments for certain plans and to reflect the introduction of new types of plans, but there are inconsistencies and the qualified investment rules are difficult to understand in some cases.

Specific issues are currently under consideration. Stakeholders are invited to submit comments by July 15, 2024 as to how the qualified investment rules can be modernized on a prospective basis to improve the clarity and coherence of the registered plans regime.

Eligible tradespeople and apprentices in the construction industry are currently able to deduct up to $4,000 in eligible travel and relocation expenses per year by claiming the labour mobility deduction for tradespeople. A private member’s bill (Bill C-241) was introduced to enact an alternative deduction for certain travel expenses of tradespeople in the construction industry, with no cap on expenses, retroactive to the 2022 taxation year.

The budget announces that the government will consider bringing forward amendments to the Income Tax Act (ITA) to provide a single, harmonized deduction for tradespeople’s travel that respects the intent of Bill C-241.

The budget proposes to amend the ITA to exclude from taxation the income of the trusts established under the First Nations Child and Family Services, Jordan’s Principle, and Trout Class Settlement Agreement. This will also ensure that payments received by class members as beneficiaries of the trusts will not be included when computing income for federal income tax purposes.

This measure will apply to the 2024 and subsequent taxation years.

Business tax measures

The 2023 budget proposed a refundable ITC for clean electricity, equal to 15% of the capital cost of eligible property. The 2024 budget provides the design and implementation details of the ITC, including the eligibility criteria. It also includes special rules for property that generates electricity from natural gas with carbon capture and property used to transmit electrical energy between provinces or territories, as well as details of the compliance and recovery process.

The ITC will be available only to eligible Canadian corporations, which are defined as:

• taxable Canadian corporations and pension investment corporations
• provincial and territorial Crown corporations (subject to additional requirements)
• corporations owned by municipalities or Indigenous communities

Property eligible for the ITC includes equipment used to generate electricity from:

• solar, wind or water energy (certain class 43.1 property, but hydroelectric installations would not be subject to a capacity limit)
• concentrated solar energy (as defined for the purposes of the proposed clean technology ITC)
• nuclear fission, including heat generating equipment (as defined for the purposes of the proposed clean technology ITC, without the generating capacity limits and other certain requirements of that credit)
• geothermal energy, including heat generating equipment, if it is used exclusively for that purpose (excluding equipment that is part of a system that extracts fossil fuel for sale)
• specified waste materials, as part of a system

Eligible property also includes equipment that is:

• stationary electricity storage equipment and equipment used for pumped hydroelectric energy storage (excluding any that uses a fossil fuel in operation)
• part of an eligible natural gas energy system (special rules apply)
• used for transmission of electricity between provinces and territories (special rules apply)

Previously proposed labour requirements must be met to qualify for the 15% ITC, otherwise a 5% ITC is available. The ITC will be subject to potential repayment obligations, repayable in proportion to the FMV of the particular property when it has been converted to an ineligible use, exported from Canada, or disposed of.

The ITC will be available for new eligible property (i.e. has not been used for any purposes before its acquisition) that is acquired and becomes available for use after April 15, 2024 and before 2035 in respect of projects that did not begin construction before March 28, 2023.

The budget introduces the EV supply chain ITC, equal to 10% of the cost of buildings used in Canada in the following electric vehicle supply chain segments:

• electric vehicle assembly
• electric vehicle battery production
• cathode active material production

To qualify for the ITC, the taxpayer (or member of a group of related taxpayers) must claim the clean technology manufacturing ITC (CTMITC) in all three of the segments (or must claim the CTMITC in two of the three segments and hold at least a qualifying minority interest in an unrelated corporation that claims the CTMITC in the third segment – the building costs of the unrelated corporation would also qualify for the new ITC).

The ITC is effective for property that is acquired and becomes available for use after December 31, 2023. The ITC will be reduced to 5% for 2033 and 2034 and 0% after 2034. Design and implementation details of the ITC will be provided in the 2024 Fall Economic Statement.

The 2023 budget proposed a clean technology manufacturing ITC, and draft legislative proposals were released in December 2023. The 2024 budget proposes to update the clean technology manufacturing ITC for production of qualifying minerals (such as copper, nickel, cobalt, lithium, graphite and rate earth elements) that occur at polymetallic projects (i.e. projects engaged in the production of multiple minerals) by:

• clarifying that the value of qualifying materials will be used as the appropriate output metric when assessing the extent to which property is used (or expected to be used) for qualifying mineral activities producing qualifying materials
• modifying eligible expenditures to include investments in eligible property used in qualifying mineral activities that are expected to produce primarily qualifying materials at mine or well sites, including tailing ponds and mills located at these sites (50% or more of the financial value of the output comes from qualifying materials)

A safe harbour rule will apply to the recapture rule for all qualifying mineral activities, to mitigate against the effects of mineral price volatility on the potential recapture of the ITC, the details of which will be provided at a later date.

Accelerated Capital Cost Allowance (CCA)

Purpose-built rental housing.

The budget provides an accelerated CCA of 10% for new eligible purpose-built rental projects that begin construction after April 15, 2024 and before January 1, 2031, and are available for use before January 1, 2036.

Eligible property will be new purpose-built rental housing that is a residential complex:

• with at least four private apartment units, or 10 private rooms or suites, and
• in which at least 90% of residential units are held for long-term rental

The Accelerated Investment Incentive (AII), which suspends the half-year rule, will continue to apply to eligible property put in use before 2028. The accelerated CCA will not apply to renovations of existing residential complexes, but new additions to an existing structure will be eligible. Projects that convert existing non-residential real estate into a residential complex will be eligible.

Productivity-enhancing assets

The budget provides immediate expensing (i.e. a 100% first-year CCA deduction) for property that is acquired after April 15, 2024 and becomes available for use before January 1, 2027, for the following CCA classes of assets:

• class 44 (patents or rights to use patented information for a limited or unlimited period)
• class 46 (data network infrastructure equipment and related systems software)
• class 50 (general-purpose electronic data-processing equipment and systems software)

The accelerated CCA will be available only for the year in which the property becomes available for use. For a short taxation year, the accelerated CCA must be prorated and will not be available in the following taxation year. Property that becomes available for use after 2026 and before 2028 will continue to benefit from the AII.

Property that has been used (or acquired for use) for any purpose before it is acquired by the taxpayer will be eligible for the accelerated CCA only if both of the following conditions are met:

• neither the taxpayer nor a non-arm’s length person previously owned the property, and
• the property has not been transferred to the taxpayer on a tax-deferred “rollover” basis

The excessive interest and financing expenses limitation (EIFEL) rules restrict a Canadian taxpayer’s deductions for interest and financing expenses, based upon a percentage of its “tax-EBITDA” (i.e. its taxable income, adjusted for items such as interest expenses, depreciation and amortization). For a discussion of the EIFEL rules, see our  Tax Insights “ Bill C-59 ─ Excessive interest and financing expenses limitation (EIFEL) regime .” The EIFEL rules currently include a single sector-specific exemption, for certain interest and financing expenses relating to public-private partnership (P3) infrastructure projects. The budget proposes to extend this election, on an elective basis, for certain interest and financing expenses relating to arm’s length financing that is used to build or acquire certain purpose-built rental housing located in Canada. This exemption will be effective for taxation years beginning after September 30, 2023, consistent with the EIFEL rules more generally. However, this exemption will be available only for expenses incurred before January 1, 2036.

The government is concerned that some landowners are holding residentially zoned vacant land as a speculative investment. The budget announces that the government will consider introducing a new tax on residentially zoned vacant land to spur development. The government will launch consultations later this year.

In March 2024, the government began consultations on how federal policies can better support the needs of all Canadians seeking to become homeowners. The government will provide an update in the 2024 Fall Economic Statement.

The budget announces the government’s intention to restrict the acquisition of existing single-family homes by very large corporate investors. The government will consult in the coming months and provide further details in the 2024 Fall Economic Statement.

The budget announces that the government is exploring new measures to expand access to alternative financing products for home purchasers, such as halal mortgages. These measures could include changes in the tax treatment of these products or a new regulatory regime for financial service providers, while ensuring adequate consumer protections are in place.

The budget proposes several amendments to the CRA’s information gathering provisions in the ITA, with the intent of enhancing the efficiency and effectiveness of tax audits and facilitating the collection of tax revenues on a timelier basis. These changes include:

• allowing the CRA to issue a new type of notice, referred to as a “notice of non-compliance” and to levy a monetary penalty
• permitting the CRA to specify that any required information (oral or written) or documents be provided under oath or affirmation
• imposing a penalty when the CRA obtains a compliance order against a taxpayer, and
• extending the stop the clock rules (which suspend the counting of days in the assessment limitation period), so that these rules apply when a taxpayer seeks judicial review of any requirement or notice issued to the taxpayer by the CRA in relation to the audit and enforcement process, and during any period that a notice of non-compliance is outstanding

Analogous amendments are also proposed to other federal tax statutes administered by the CRA. The budget also proposes certain technical amendments to ensure the rules meet their policy objectives.

These amendments would come into force upon royal assent of the enacting legislation.

The ITA allows a corporation to deduct the amount of any dividends received on a share of a corporation resident in Canada, subject to certain limitations.

One of these limitations is an anti-avoidance rule that denies the dividend received deduction in connection with synthetic equity arrangements. Synthetic equity arrangements include arrangements in which a person receives a dividend on a share, but all or substantially all of the risk of loss and opportunity for gain or profit (the “economic exposure”) in respect of the share are provided to another person.

Where a taxpayer enters into a synthetic equity arrangement in respect of a share, the taxpayer is generally obligated to compensate the other person for the amount of any dividends paid on the share. This compensation payment may result in a tax deduction for the taxpayer in addition to the dividend received deduction. Unless the anti-avoidance rule applies to deny the dividend received deduction, a tax loss would generally arise as a result of the two deductions.

The anti-avoidance rule incorporates certain exceptions, including where the taxpayer establishes that no tax-indifferent investor has all or substantially all of the economic exposure in respect of the share. An associated exception is also available for synthetic equity arrangements traded on a derivatives exchange.

The budget proposes to remove the tax-indifferent investor exception (including the exchange traded exception) to the anti-avoidance rule. This measure would prevent taxpayers from claiming the dividend received deduction for dividends received on a share in respect of which there is a synthetic equity arrangement.

This measure would apply to dividends received after December 31, 2024.

A mutual fund is a type of investment vehicle that allows investors to pool their money and invest in a portfolio of investments without purchasing the investments directly. A mutual fund corporation is a mutual fund organized as a corporation that meets certain conditions set out in the ITA.

The ITA includes special rules for mutual fund corporations that facilitate conduit treatment for investors (shareholders). For example, these rules generally allow capital gains realized by a mutual fund corporation to be treated as capital gains realized by its investors. In addition, a mutual fund corporation is not subject to mark-to-market taxation and can elect capital gains treatment on the disposition of Canadian securities.

To qualify as a mutual fund corporation under the ITA, a corporation must satisfy several conditions, including that it must be a “public corporation”. A corporation can meet this condition if a class of its shares is listed on a designated stock exchange in Canada. A corporation that is controlled by a corporate group may satisfy this condition, and qualify as a mutual fund corporation, even though it is not widely held. The government is concerned that this could allow a corporate group to use a mutual fund corporation to benefit from the special rules available to these corporations in an unintended manner.

Although the government believes this planning can be challenged based on existing rules in the ITA, the budget proposes specific amendments to the ITA to preclude a corporation from qualifying as a mutual fund corporation where it is controlled by or for the benefit of a corporate group (including a corporate group that consists of any combination of corporations, individuals, trusts, and partnerships that do not deal with each other at arm’s length). Exceptions would be provided to ensure that the measure does not adversely affect mutual fund corporations that are widely held pooled investment vehicles.

This measure would apply to taxation years that begin after 2024.

The budget introduces the Canada Carbon Rebate for Small Business, to return a portion of the federal backstop pollution pricing fuel charge proceeds collected from a province. This will be an automatic refundable tax credit for CCPCs with less than 500 employees in Canada in the calendar year in which the fuel charge begins. The tax credit in respect of the 2019-20 to 2023-24 fuel charge years will be available to a CCPC that files a tax return for its 2023 taxation year by July 15, 2024 (with similar timelines for future fuel charge years).

The tax credit amount:

• is determined for each applicable province in which the eligible corporation had employees in the calendar year in which the fuel charge year begins; and
• is equal to the number of persons employed by the eligible corporation in the province in that calendar year multiplied by a payment rate specified by the Minister of Finance for the province for the corresponding fuel charge year

The ITA includes an anti-avoidance rule that is intended to prevent taxpayers from avoiding payment of their tax liabilities by transferring their assets to non-arm’s length persons. The effect of this tax debt avoidance rule is to make the transferee jointly and severally, or solidarily, liable with the transferor for the transferor’s tax debts, to the extent that the value of the property transferred exceeds the amount of consideration given by the transferee for the property.

The ITA contains a number of rules that address various planning techniques employed by taxpayers attempting to circumvent the tax debt avoidance rule, as well as a penalty for those who engage in, participate in, assent to, or acquiesce in planning activity that they know, or would reasonably be expected to know, is tax debt avoidance planning.

The budget includes a new specific measure to address tax debt avoidance planning (although the government believes this planning can also be challenged based on existing rules in the ITA). The measure would apply in the following circumstances:

• there has been a transfer of property from a tax debtor to another person
• as part of the same transaction or series of transactions, there has been a separate transfer of property from a person other than the tax debtor to a transferee that does not deal at arm’s length with the tax debtor, and
• one of the purposes of the transaction or series is to avoid joint and several, or solidary, liability

Where these conditions are met, the property transferred by the tax debtor would be deemed to have been transferred to the transferee for the purposes of the tax debt avoidance rule. This would ensure that the tax debt avoidance rule applies in situations where property has been transferred from a tax debtor to a person and, as part of the same transaction or series, property has been received by a non-arm’s length person. The penalty applicable to those who participate in tax debt avoidance planning would also be extended to this proposed new rule.

In many cases, tax debt avoidance planning is facilitated by a planner who receives a significant fee, which is effectively funded by a portion of the avoided tax debt. The courts have held that a taxpayer who engages in tax debt avoidance planning is normally not jointly and severally, or solidarily, liable for the portion of the tax debt that has effectively been retained by the planner as a fee. The budget proposes that taxpayers who participate in tax debt avoidance planning be jointly and severally, or solidarily, liable for the full amount of the avoided tax debt, including any portion that has effectively been retained by the planner.

Similar amendments would be made to comparable provisions in other federal statutes.

These measures would apply to transactions or series of transactions that occur after April 15, 2024.

The ITA includes a general rule providing that a person who fails to file or make a return or comply with certain specified rules is guilty of an offence, and liable to penalties of up to $25,000 and imprisonment for up to a year. The mandatory disclosure rules in the ITA also include specific penalties that apply in these circumstances, making the application of this general penalty provision unnecessary.

The budget therefore proposes to remove from the scope of the general penalty provision the failure to file an information return in respect of a reportable or notifiable transaction under the mandatory disclosure rules.

This amendment would be deemed to have come into force on June 22, 2023, which is the day the enhanced mandatory disclosure rules received royal assent.

Under the ITA, losses and other tax attributes that arise from expenditures for which a taxpayer did not ultimately bear the cost are generally not recognized. The ITA contains a set of debt forgiveness rules that apply where a commercial debt is settled for less than its principal amount. These rules generally reduce tax attributes by the amount of debt that is forgiven and, where tax attributes have been fully reduced, the rules cause an income inclusion equal to half of the remaining forgiven amount. The ITA also contains a rule that entitles an insolvent corporation to a corresponding deduction to offset all or part of an income inclusion from the debt forgiveness rules.

Bankrupt taxpayers are generally excluded from these debt forgiveness rules. Instead, a separate loss restriction rule applies to extinguish the losses of bankrupt corporations that have received an absolute order of discharge.

The government is concerned that some taxpayers have sought to manipulate the bankrupt status of an insolvent corporation, with a view to benefiting from the exception in the debt forgiveness rules while also avoiding the loss restriction rule applicable to bankrupt corporations. This planning seeks to preserve the losses and other tax attributes of the insolvent corporation (which would otherwise be eliminated upon the forgiveness of its debts), so that these attributes can be acquired and used by a profitable corporation. This planning is the subject of a designated transaction under the notifiable transactions element of the mandatory disclosure rules.

Although the government believes that manipulation of bankrupt status can be challenged based on existing rules in the ITA, the budget proposes a specific legislative measure to address this issue: repealing the exception to the debt forgiveness rules for bankrupt corporations and the loss restriction rule applicable to bankrupt corporations. This change would subject bankrupt corporations to the general rules that apply to other corporations whose commercial debts are forgiven. The bankruptcy exception to the debt forgiveness rules would remain in place for individuals. While bankrupt corporations would be subject to the reduction of their loss carryforward balances and other tax attributes upon debt forgiveness, as insolvent corporations they could qualify for relief from the debt forgiveness income inclusion rule provided under the existing deduction for insolvent corporations.

These proposals would apply to bankruptcy proceedings that are commenced on or after April 16, 2024.

Scientific Research and Experimental Development (SR&ED)

The government launched a consultation on the existing SR&ED tax incentives on January 31, 2024, which closed on April 15, 2024. The budget announces a second phase of consultations, to focus on specific policy parameters, explore how Canadian public companies could become eligible for the enhanced SR&ED ITC and inform how additional funding announced by the budget can support future enhancements to the SR&ED program. Further details of the consultation will be released on the Department of Finance Canada website at a later date.

International tax measures

The Organisation for Economic Co-operation and Development (OECD) has developed a framework for the automatic exchange of tax information relating to transactions in crypto-assets, the Crypto-Asset Reporting Framework (CARF). The budget proposes to implement the CARF in Canada. The new reporting rules will apply to crypto-asset service providers that are resident in Canada, or carry on business in Canada, and that provide services effectuating exchange transactions in crypto-assets. These service providers will need to report certain information regarding their customers and crypto-asset transactions. The budget also includes proposed amendments to the Canadian rules implementing the OECD’s Common Reporting Standard, including changes relating to electronic money products and central bank digital currencies. These measures will apply to 2026 and subsequent calendar years.

A person who makes a payment to a non-resident for services rendered in Canada is currently required to withhold 15% of the payment and remit that amount to the CRA. This is intended to serve as a prepayment of tax that the non-resident may ultimately owe in Canada. Certain non-residents do not owe Canadian tax for these services, e.g. due to exemptions in tax treaties, or exemptions for specific activities like international shipping. In these circumstances, the CRA may provide an advance waiver from the withholding obligation for specific transactions, or the non-residents may apply for refunds of amounts that have already been withheld. The budget proposes to give the CRA legislative authority to grant single waivers that cover multiple transactions occurring over a specific time period, where certain conditions are satisfied. This measure will take effect upon royal assent of the enacting legislation.

The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting has developed a two-pillar plan to reform the international tax system, as part of the “BEPS 2.0” initiative. On October 8, 2021, Canada and 135 other countries in the Inclusive Framework committed to adopt this plan (for a discussion on that commitment, see our  Tax Insights  “ The new international tax framework and Canada’s digital services tax ”). The budget provides an update on the two pillars of this international tax reform initiative.

Pillar One will introduce new rules for allocating taxing rights between countries to address challenges raised by the digital economy. These rules will generally apply to multinational enterprises (MNEs) with annual revenue above €20 billion and profit margins above 10%. The right to tax a portion of these MNEs’ profits will be reallocated to market countries (i.e. the countries where the MNEs’ users and customers are located).

The budget reaffirms Canada’s commitment to bringing Pillar One into effect as soon as a critical mass of countries is willing to participate. In the meantime, Canada is moving ahead with its plan to enact the Digital Services Tax (DST). Implementing legislation for the DST is currently before Parliament in Bill C-59. The DST will take effect beginning in calendar year 2024, with the first year covering taxable revenues earned since January 1, 2022. (For a discussion of the DST, see our  Tax Insights  “ Digital Services Tax: One step closer to becoming a reality .”)

Pillar Two will introduce a 15% global minimum tax. This tax will generally apply to MNEs with global revenues of at least €750 million. These MNEs will be required to compute their effective tax rate (ETR) in each country where they operate. If the ETR for a particular country is below 15%, a top-up tax will be imposed, to raise that ETR to 15% (this top-up tax may be reduced by a substance-based income exclusion, which is computed based on the payroll costs and net book value of tangible assets located in the jurisdiction). Draft legislative proposals for a Global Minimum Tax Act to implement the Pillar Two regime in Canada were released for public comment in August 2023 (for a discussion of those proposals, see our  Tax Insights  “ Canada releases draft Global Minimum Tax Act ”). The budget states that Canada is moving forward with this implementing legislation and intends to introduce it in Parliament soon.

Sales tax measures

Extending goods and services tax (gst) relief to student residences.

On September 14, 2023, the government announced that it would temporarily remove the GST from new purpose-built rental housing projects (i.e. apartment buildings, student housing and senior residences built specifically for long-term rental accommodation) by implementing an Enhanced (100%) GST Rental Rebate for new qualifying purpose-built rental housing projects (for more information, see our  Tax Insights  “ Enhanced GST rental rebate for rental apartments that begin construction after September 13, 2023 ").

To ensure that universities, public colleges and school authorities can also claim the Enhanced (100%) GST Rental Rebate for student residences that are built for short-term use, the budget proposes to amend the  Excise Tax Act  to allow them to apply the normal GST/Harmonized sales tax (HST) rules that apply to other builders (i.e. paying GST/HST on the final value of the building) in respect of new student housing projects.

The budget also proposes to relax the rebate conditions so that universities, public colleges and school authorities that operate on a not-for-profit basis (i.e. those that would currently qualify for the Public Service Body rebates under the GST/HST) can claim the 100% rebate in respect of any new student residence that they acquire or construct provided it is primarily for the purpose of providing a place of residence for their students.

The proposed measures would apply to student residences that begin construction after September 13, 2023 and before 2031, and that complete construction before 2036.

The budget proposes to repeal the temporary zero rating of certain face masks or respirators and certain face shields under the GST/HST for supplies made after April 30, 2024.

Previously Announced Measures

The budget confirms that the government will proceed with the following previously announced measures, as modified to take into account consultations, deliberations and legislative developments since their announcement or release:

• legislative proposals released on December 20, 2023, which include measures relating to the clean hydrogen ITC, the clean technology manufacturing ITC, concessional loans and short-term rentals
• legislative and regulatory proposals announced in the 2023 Fall Economic Statement, which include measures relating to the Canadian journalism labour tax credit, the expansion of eligibility for the clean technology and clean electricity ITC, the GST/HST joint venture election rules and the Underused Housing Tax
• legislative and regulatory amendments to implement the Enhanced (100%) GST Rental Rebate for purpose-built rental housing announced on September 14, 2023
• the carbon capture, utilization and storage and the clean technology ITCs and labour requirements related to certain “clean economy” ITCs
• enhancing the reduced tax rates for zero-emission technology manufacturers
• flow-through shares and the critical mineral exploration tax credit – lithium from brines
• Retirement Compensation Arrangements
• strengthening the Intergenerational Business Transfer framework
• the income tax and GST/HST treatment of credit unions
• a tax on repurchases of equity
• modernizing the General Anti-Avoidance Rule
• global minimum tax and DST
• technical amendments to GST/HST rules for financial institutions
• providing relief in relation to the GST/HST treatment of payment card clearing services
• extending the quarterly duty remittance option to all licensed cannabis producers
• revised Luxury Tax draft regulations to provide greater clarity on the tax treatment of luxury items
• technical tax amendments to the ITA and the Income Tax Regulations
• legislative amendments to implement changes discussed in the transfer pricing consultation paper released on June 6, 2023
• tax measures announced in the 2023 budget, including the dividend received deduction by financial institutions
• substantive CCPCs
• technical amendments to the ITA and Income Tax Regulations
• legislative amendments to implement the hybrid mismatch arrangements rules announced in the 2021 budget

The budget also reaffirms the government’s commitment to move forward, as required, with technical amendments to improve the certainty and integrity of the tax system.

Integration – Capital gains ($)

(taxation year ended December 31, 2024, and $10,000 of capital gains earned after June 24, 2024)

This table shows:

• the income tax deferral (prepayment) if capital gains in excess of $250,000 are earned and retained in a corporation as opposed to being earned directly by an individual
• the tax (cost) if the after-tax corporate income is paid out as a dividend to the shareholder in 2024

The table assumes:

• the individual is in the top marginal tax rate
• no capital gains deductions are available
• the non-taxable portion of the capital gain is distributed as a tax-free capital dividend
• the taxable dividend paid is sufficient to generate a full refund of refundable tax 

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Tax Insights: 2024 Federal budget ─ Supporting housing, raising taxes

Dean Landry

National Tax Leader, PwC Canada

Tel: +1 416 815 5090

© 2018 - 2024 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.

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Moscow Metro Tour

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Description

Moscow metro private tours.

• 2-hour tour $87:  10 Must-See Moscow Metro stations with hotel pick-up and drop-off
• 3-hour tour $137:  20 Must-See Moscow Metro stations with Russian lunch in beautifully-decorated Metro Diner + hotel pick-up and drop off. 
• Metro pass is included in the price of both tours.

Highlight of Metro Tour

• Visit 10 must-see stations of Moscow metro on 2-hr tour and 20 Metro stations on 3-hr tour, including grand Komsomolskaya station with its distinctive Baroque décor, aristocratic Mayakovskaya station with Soviet mosaics, legendary Revolution Square station with 72 bronze sculptures and more!
• Explore Museum of Moscow Metro and learn a ton of technical and historical facts;
• Listen to the secrets about the Metro-2, a secret line supposedly used by the government and KGB;
• Experience a selection of most striking features of Moscow Metro hidden from most tourists and even locals;
• Discover the underground treasure of Russian Soviet past – from mosaics to bronzes, paintings, marble arches, stained glass and even paleontological elements;
• Learn fun stories and myths about Coffee Ring, Zodiac signs of Moscow Metro and more;
• Admire Soviet-era architecture of pre- and post- World War II perious;
• Enjoy panoramic views of Sparrow Hills from Luzhniki Metro Bridge – MetroMost, the only station of Moscow Metro located over water and the highest station above ground level;
• If lucky, catch a unique «Aquarelle Train» – a wheeled picture gallery, brightly painted with images of peony, chrysanthemums, daisies, sunflowers and each car unit is unique;
• Become an expert at navigating the legendary Moscow Metro system;
• Have fun time with a very friendly local;
• + Atmospheric Metro lunch in Moscow’s the only Metro Diner (included in a 3-hr tour)

Hotel Pick-up

Metro stations:.

Komsomolskaya

Novoslobodskaya

Prospekt Mira

Belorusskaya

Mayakovskaya

Novokuznetskaya

Revolution Square

Sparrow Hills

+ for 3-hour tour

Victory Park

Slavic Boulevard

Vystavochnaya

Dostoevskaya

Elektrozavodskaya

Partizanskaya

Museum of Moscow Metro

• Drop-off  at your hotel, Novodevichy Convent, Sparrow Hills or any place you wish
• + Russian lunch  in Metro Diner with artistic metro-style interior for 3-hour tour

Fun facts from our Moscow Metro Tours:

From the very first days of its existence, the Moscow Metro was the object of civil defense, used as a bomb shelter, and designed as a defense for a possible attack on the Soviet Union.

At a depth of 50 to 120 meters lies the second, the coded system of Metro-2 of Moscow subway, which is equipped with everything you need, from food storage to the nuclear button.

According to some sources, the total length of Metro-2 reaches over 150 kilometers.

The Museum was opened on Sportivnaya metro station on November 6, 1967. It features the most interesting models of trains and stations.

Coffee Ring

The first scheme of Moscow Metro looked like a bunch of separate lines. Listen to a myth about Joseph Stalin and the main brown line of Moscow Metro.

Zodiac Metro

According to some astrologers, each of the 12 stops of the Moscow Ring Line corresponds to a particular sign of the zodiac and divides the city into astrological sector.

Astrologers believe that being in a particular zadiac sector of Moscow for a long time, you attract certain energy and events into your life.

Paleontological finds 

Red marble walls of some of the Metro stations hide in themselves petrified inhabitants of ancient seas. Try and find some!

• Every day each car in  Moscow metro passes  more than 600 km, which is the distance from Moscow to St. Petersburg.
• Moscow subway system is the  5th in the intensity  of use (after the subways of Beijing, Tokyo, Seoul and Shanghai).
• The interval in the movement of trains in rush hour is  90 seconds .

What you get:

• + A friend in Moscow.
• + Private & customized Moscow tour.
• + An exciting pastime, not just boring history lessons.
• + An authentic experience of local life.
• + Flexibility during the walking tour: changes can be made at any time to suit individual preferences.
• + Amazing deals for breakfast, lunch, and dinner in the very best cafes & restaurants. Discounts on weekdays (Mon-Fri).
• + A photo session amongst spectacular Moscow scenery that can be treasured for a lifetime.
• + Good value for souvenirs, taxis, and hotels.
• + Expert advice on what to do, where to go, and how to make the most of your time in Moscow.

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