DFK Tax Digest – 2023 Issue Four

  • The New Trust Filing Rule Could be a Real “Bare” to Deal With – There are new reporting rules related to filing of Trust tax returns that become effective for Trusts with a December 31, 2023 year end or later. These new rules result in two significant filing changes.
  • Summary of the Bill C-208 Rules coming into place for transfers effective January 1, 2024 – As proposed in Budget 2023 (further revised August 4, 2023) and where conditions are met and an election is made, the business transfer between a parent and a corporation controlled by a child is excluded from the Section 84.1 deemed dividend rules. The original Bill C-208 rules introduced in 2021 have now become much more complex with rigorous requirements intended to reflect a more genuine intergenerational transfer of a business applicable to transactions dated January 1, 2024, and later.