The most significant Canadian tax technical bill in over a decade (Bill C-48) is now law, receiving royal assent on June 26, 2013.  The bill included over 900 pages of technical amendments that impact foreign affiliates, non-resident trusts, offshore investment fund property and a wide variety of other areas.  Most of these technical amendments apply retroactively (such as to the date the amendments were first proposed), and in some cases elections are available to apply certain transitional rules or to extend the effective dates further back. 

The provisions in the bill were originally set out in a Notice of Ways and Means Motion that was released on October 24, 2012. To access our commentary from 2012 on the main topics that were included in the bill, please click on the relevant link below: 

Navigating these various technical amendments is often difficult. As many of the changes may apply to current and certain past taxation years (either automatically or on an elective basis); it is important to review current and past transactions to determine the impact of the changes and the advisability of making any of the permitted elections.