Year: 2024

GST/HST New Residential Rental Property Rebates – Where Do We Currently Stand?

Posted on by dflanagan

On September 14, 2023, the Department of Finance announced a new enhanced GST/HST New Residential Rental Property Rebate (“NRRPR”) for certain New Purpose-Built Rental Housing (“PBRH”).  The purpose of the enhanced rebate is to provide relief on the GST costs related to building new residential rental properties in order to assist with stimulating build of PBRH.

Background

The rental of a residential complex or a residential unit in a residential complex is generally exempt for GST/HST purposes. Therefore, builders cannot claim HST paid in relation to these properties.  Typically, the major GST/HST cost is paid or payable on the purchase of a residential complex from a builder or that they accounted for on the “self-supply” of the complex.

However, eligible residential builders can file for the NRRP Rebate for the GST up to a maximum of 36% of the GST payable on the purchase or self-supply of a qualifying residential unit (an Ontario NRRP HST rebate is also available in that province). The amount of the NRRP Rebate is progressively reduced when the fair market value (“FMV”) of the property exceeds $350,000 (no NRRP Rebate is available if the fair market value is $450,000 or more).  Further, the Ontario NRRP Rebate becomes capped at $24,000, which can result in significant GST/HST costs to builders.

Pursuant to the PBRH Rebate rules, to the extent the new residential rental project meets certain requirements, the rebate percentage is increased from 36% to 100%. Moreover, the PBRH Rebate does not have any phasing-out rule or the $450,000 fair market value limitation per unit.

PBRH – What Properties Qualify?

The PBRH Rebate is only available for a residential unit that qualifies for all the following conditions:

  1. Construction has begun after September 13, 2023, and on or before December 31, 2030;
  2. Construction is substantially completed by December 31, 2035; and
  3. It is in a building with at least:
    a. Four private apartment units (i.e., a unit with a private kitchen, bathroom, and living areas), or at least 10 private rooms or suites; and
    b. 90% of residential units designated for long-term rental.

An “addition” to an existing building also qualifies to the extent that such addition includes 4 or more residential units and at least 4 of those units contain private kitchen, bath, and living area (or 10 or more private rooms or suites).

The purpose of this legislation is to increase the supply of new residential properties, therefore, existing residential complexes that undergo a substantial renovation do not qualify for the PBRH.

What is Considered “Construction” to the Canada Revenue Agency (“CRA”)?

Those involved in the construction industry will know there are various stages of “construction”, and this is a crucial element of builders being eligible for the PBRH.  The term “construction” is not defined in the Excise Tax Act (“ETA”) which has left many builders wondering what CRA considers “construction”.

On June 20, 2024, the CRA published new GST/HST Notice 336 (“336”). Included in 336 is the CRA’s comments and administrative view that states CRA’s position is that the construction of a residential complex is generally considered to begin at the time the excavation work pertaining to the property. CRA also implies that the signing of a purchase and sale agreement relating to a newly constructed units prior to September 14, 2023, would not prevent the builder’s eligibility for the PBRH Rebate if the construction of the complex began after September 13, 2023, but before 2031. CRA also confirms that newly constructed long-term care facilities that otherwise meet the relevant conditions would be eligible for the PBRH Rebate.

Although the CRA announcement from June of 2023 is welcomed, there is still remains some subjectivity.  The CRA announcement is an administrative position, meaning, it isn’t legislation – which comes with some element of risk.  For instance, there are many stages of excavation work, including the initial clearing of land.  It appears that further clarification will still be required, which will likely come in the form of taxpayer’s disputing what “construction” is, as CRA challenges these rebate filings.

 

Considerations When Preparing Guideline Public Company Multiples for a Private Business

Posted on by Edixon

Among the approaches or methodologies employed by business valuators to determine the value of a business or equity interest is the market approach. The market approach determines the value of a business or equity interest using one or more methodologies that compare the subject business to similar assets, businesses, business ownership interests, and securities that have been sold or publicly traded. The advantages of using the market approach eliminates some subjective estimates and uses data that is readily available and verifiable. Two commonly applied methods under the market approach are the guideline public company method and the precedent transaction method. In this article, we will focus on the guideline public company method.

The guideline public company methodology is a useful tool in determining the value of a business or equity interest by comparing the subject company to similar companies that are publicly traded. This allows a private business to better understand the price it might receive if it was to trade publicly, based on public companies within a similar industry and similarly sized operations.

There are three steps to prepare a guideline public company comparison:

  1. Identifying a list of comparable publicly traded companies and calculating applicable valuation multiples. A valuation multiple is applied to a financial measure such as normalized earnings before interest, taxes, depreciation, and amortization (EBITDA) to develop the value of a business;
  2. Adjusting the guideline public company multiples based on the relative size and risk of the comparable public companies in relation to the subject company; and
  3. Applying the selected multiples, after any adjustments, to the subject company/interest in order to determine its value.
Identifying comparable public companies and calculating valuation multiples

When identifying comparable public companies, it is important to consider the industry, operation size, location, risk, and diversity of revenue streams of the subject company. For each variable, consider the impact of relevant differences between the selected public comparable companies and the subject company. For example, classifying a restaurant into a full-service restaurant industry versus the fast-food limited service industry could result in different market multiples. Similarly, diversified companies are expected to have different market multiples compared to companies that engage in a specific line of business.

A common misconception is selecting more public companies, will result in a better analysis when the public companies may not be truly comparable to the subject company. Ideally, an average of a number or group of comparable public companies should be used for an accurate analysis.

Once a set of public comparable companies have been identified, valuation multiples are calculated using either the Enterprise Value or Equity Value. Both can be applied to earnings before interest and taxes (EBIT), EBITDA, revenue, or even nonfinancial measures. When calculating the valuation multiples, review the public company’s financial reports for one-time adjustments that may affect EBITDA or the selected measure. The most common valuation multiples use the Enterprise Value, being the “debtfree” approach. The Equity Value may be more relevant and reliable for equity valuations. See our Spring/ Summer 2022 issue of the FSAT News for an in-depth discussion on the differences between Enterprise Value and Equity Value.

Adjusting guideline public company multiples for comparability to private companies

Professional judgment is required to determine the potential discounts that is applicable to the subject company. For example, an inherent minority discount applicable to public traded companies may offset a liquidity discount that is applicable to smaller private companies. The following are common discounts to public company valuation multiples when valuing smaller private companies:

Liquidity discount: The amount by which the en bloc value of a business or ratable value of an interest therein is reduced in recognition of the expectation that the business or equity interest cannot be readily converted to cash.

Minority discount: The reduction from the pro rata portion of the en bloc value of the assets or ownership interests of a business as a whole to reflect the disadvantages of owning a minority shareholding.

Size discount: Large, diversified, and attractive businesses may have little or no discount, whereas smaller companies may have considerable discounts.

Applying selected valuation multiples

Finally, prior to applying the selected Enterprise or Equity Value multiples to the subject company, ensure the earnings of the subject company are “normalized” so they are representative of future maintainable earnings and are similar to the earning measure of the comparable public companies.

The market approach is often used as a secondary methodology or to assess the reasonability of a valuation conclusion. However, it can also be an informative first step if you are considering selling your business or adding a shareholder. To ensure you consider accurate guideline public comparable companies multiples for your business, one of our valuation specialists may be able to assist.

Canada Pension Plan: Changes to Certain Benefits

Posted on by dflanagan

Several changes have been introduced to targeted measures and benefits under the Canada Pension Plan (CPP). None of the below changes are expected to impact contribution rates.

Death benefit

The CPP death benefit is increased to $5,000 (from $2,500) where all of the following criteria are met:

  • the estate would otherwise be eligible for the regular death benefit;
  • the deceased had not received any retirement or disability benefits, or similar benefits under a provincial pension plan; and
  • no survivor’s benefit is payable as a result of the individual’s death.

The increased benefit applies to deaths after December 31, 2024.

Children’s benefits

Prior to the change, the CPP surviving child benefit was only payable to children of a deceased parent if the child was under 18 or between the ages of 18 and 25 and was a fulltime student. While this benefit is still available, a similar benefit has now been introduced for part-time students, equal to 50% of the amount payable to full-time students.

In addition, eligibility for the disabled contributor’s child benefit is extended such that it continues to be available even when the disabled parent reaches age 65. Previously, the benefit ended when the disabled parent reached age 65.

Survivor benefits

Previously, couples who were legally separated but still married or in a common-law relationship could be eligible for CPP survivor pension on their partner’s passing. However, after this change, the survivor pension is not payable after a legal separation where there has been a division of their CPP pensionable earnings following the separation.

Ensure you apply for these enhanced benefits if you are eligible.

Application Intake Starting Soon for Agri-food Producers and Processors Funding Program

Posted on by dflanagan

On October 8, 2024, the Government of Canada and Ontario announced $4M in funding that will be available for agri-food producers and processors. Funded through the Sustainable Canadian Agricultural Partnership (Sustainable CAP), the investment will strengthen Ontario’s agri-food workforce.

Applications for this initiative will be accepted on October 22, 2024, for eligible primary producers, processors, and industry organizations.

Program Benefits

  • Eligible producers & processors can receive up to 50% in cost-share support per project, up to a maximum of $40,000.
  • Eligible industry organizations and collaborations between or among businesses can receive up to 50% of their eligible costs, up to a maximum of $100,000 per project.

Learn more about this new funding program.

The Importance of Bookkeeping for Your Business

Posted on by dflanagan

Starting a business can be a stressful time for business owners with many tasks to sort through from accounting, marketing, hiring employees, and general operations – each of these tasks are important and influence the success of your business.

Bookkeeping usually ends up low on the priority list, as does the bookkeeping system that is utilized.  Often the year-end reporting is due and you find your shoebox or drawer is full of receipts, and then it becomes both daunting and overwhelming to deal with.  Creating a bookkeeping system early on can make the difference between a successful business and a failure.

A solid bookkeeping method, in conjunction with a bookkeeping system, can make it easier for you to manage your books.  Not only will this save you time, but money as well, leaving you time to work on the business.

Finding the right accounting program is just as important as finding the right accountant or lawyer.  Online accounting software such as QuickBooks and Xero can offer you the ability to run accurate and real-time reports.  The better the setup, the more meaningful the reports.

Bookkeeping is an essential part of any business and when done correctly can offer many benefits.  This task should be done as often as possible to ensure accuracy.   If time is constrained, you may want to look at outsourcing your bookkeeping to a professional. Outsourcing can reduce error and be very cost-effective.

Contact us today to learn more about how we can help!

Private Companies: How a Professional Audit Can Help You Reach Your Goals

Posted on by RSM US LLP

The ultimate goal for most private business owners is to realize the value of their hard work and be in the position to step away from their company comfortably. But many business owners are woefully unprepared for what should be the capstone of their career—selling their business or transitioning ownership to the next generation.

What is one major factor in this common problem? Many private businesses have never been audited.

If you own a private company, you should consider the risks, challenges and potential missed opportunities that can arise if you don’t have it audited on a regular basis. Whether you are entertaining an offer from a potential acquirer, bringing on a new investor or management team, or refinancing your business, you may not be making the most of these opportunities if your business isn’t audited regularly.

Based on our experience working with scores of middle market companies over the years, we have identified seven key reasons for private business owners to consider an audit, as well as a few scenarios that help to bring these ideas to life. These are based on real-world situations we have witnessed time and again in our work with private business owners.

7 reasons to have your company audited

1. You never know when the right opportunity may arise. Most business owners will tell you they don’t have any plans to sell their company, but that idea can change quickly when a potential buyer approaches with a compelling offer. Getting your business audited allows you to be ready for these opportunities when they come up.

2. When opportunities do arise, time is of the essence. If you aren’t getting a regular audit, any potential deal timelines will be extended—perhaps significantly—to make room for the initial audit process required by a proposed transaction. An extended timeline means greater risk that the deal falls through.

3. Uncertainty diminishes value. A regular audit from a reputable firm provides assurance that your company’s financial house is in order. Without such an audit, a prospective buyer will likely assume a greater level of risk as part of the transaction and therefore require more return in compensation for the risk taken. This translates to less up-front value for you as the owner.

4. Peace of mind is meaningful. Regular audits help to provide some professional oversight of company management, which can provide a degree of comfort to shareholders, especially for owners who have transitioned out of a day-to-day management role.

5. Good governance leads to resilience. A regular audit is a regular feature of a professional, established company. As a private company grows, the company’s management and processes eventually must evolve and become more professionalized.

6. Your reputation matters. While it isn’t designed to detect fraud, an audit provides a degree of assurance that a company’s finance operations are functioning properly. In addition, the lack of an audit may raise questions about the company’s professionalism and sophistication.

7. Flimsy valuations have limited value. Many private company owners may assume that a simple valuation is sufficient if and when an opportunity to sell arises. However, the rigor of an audit from a reputable firm can carry more weight in a potential transaction process.

Common scenarios shine light on the value of an audit
Scenario 1: You are planning to sell your business—whether soon or someday.

Time and again, owners who thought they would never sell end up selling because a hard-to-ignore offer comes in unexpectedly or family circumstances change suddenly. If you wait until circumstances like these arise before you get your books in order, you may miss a valuable opportunity.

A prospective buyer typically will require three years of audited financial statements. If you haven’t had your company audited as a normal course of business, the process likely won’t be as simple as receiving an offer and conducting the required audit. Annual audits going back three years can take several months to complete. Often, time is of the essence in a deal process, and a buyer may lose interest or walk away if there are delays.

Time is not the only issue. If your company is being audited for the first time in conjunction with a proposed transaction, you don’t know exactly what the audit will find. The more issues the audit uncovers, the more questions the buyer will likely ask, which may extend the due diligence process. Issues and surprises during the audit process also could cause the buyer to reassess their valuation of your company. These challenges may be mitigated by performing timely audits well before you consider selling your business.

Scenario 2: You want to transition management of the company to the next generation.

When a longtime owner’s personal or professional objectives eventually compel them to step away from their business, they will sometimes transfer management to a professional management team or perhaps to the next generation of family ownership. When these circumstances arise, it is helpful to build a layer of financial oversight between the company’s shareholders and its management team.

An audit can help serve that function. Audits provide a degree of comfort when longtime owners are no longer keeping close tabs on the company’s day-to-day operations. Shareholders may sleep better at night knowing that there is more professional oversight of senior management. The audit is not designed to find fraud, but it can inspire confidence in the accuracy of financial statements and effectiveness of controls, which can bring peace of mind to shareholders.

Scenario 3: Your company has reached a certain size, and you want to improve its governance—and protect its reputation.

As a private company grows, eventually it will no longer be feasible for a small group of individuals to know everything that is happening inside the company. Management must evolve, and governance must become more comprehensive.

A professional audit can serve a critical role in this process by:

  • Reassuring shareholders and other stakeholders—including customers and suppliers—that the company’s financial records are accurate and reliable
  • Supporting and protecting your company’s valuation
  • Speeding up due diligence for investors and lenders—should such processes be needed
  • Helping to improve your company’s reputation as best-in-class—part of a group of forward-thinking companies that are regularly audited and thus perceived as better-run and more sophisticated

In fact, once a company reaches a certain size, the lack of an annual audit may raise serious questions about the company’s sophistication and professionalism.

 
The value of an audit firm

Depending on the type of audit firm you engage, audits can also unlock additional strategic value for your company.

When a multiservice auditing firm is engaged, you can tap into its deep knowledge of your industry and best practices plus the combined intelligence of all the specialists in the audit firm. Business owners can benefit from perspective and actionable advice on multiple aspects of your business, ranging from internal controls and operations to tax planning, M&A, financing, technology and more.

By approaching the audit as an opportunity for improvement and insight, a business owner can go beyond compliance and verification and extract significant strategic value—value that could positively affect your company’s financial stability, operational efficiency and long-term success.

Source: RSM Canada LLP.
Reprinted with permission from RSM Canada LLP.
© 2024 RSM Canada LLP. All rights reserved. https://rsmcanada.com/insights/services/audit/why-every-private-company-needs-an-audit.html

RSM Canada LLP is a limited liability partnership that provides public accounting services and is the Canadian member firm of RSM International, a global network of independent assurance, tax and consulting firms. RSM Canada Consulting LP is a limited partnership that provides consulting services and is an affiliate of RSM US LLP, a member firm of RSM International. The member firms of RSM International collaborate to provide services to global clients but are separate and distinct legal entities that cannot obligate each other. Each member firm is responsible only for its own acts and omissions, and not those of any other party. Visit rsmcanada.com/about for more information regarding RSM Canada and RSM International.

Business Receipts: What is Sufficient?

Posted on by dflanagan

In a recent Tax Tip, CRA stated that an acceptable receipt for income tax purposes must contain all of the following:

  • the date of the purchase;
  • the name and address of the seller;
  • the name and address of the buyer;
  • the full description of the goods or services purchased; and
  • the vendor’s business number if the vendor is a GST/HST registrant.

Credit card statements are not generally acceptable unless they contain all the above information.

To avoid disputes when claiming deductions, ensure that receipts contain all the required information.

Modernization Strategies for the Not-for-Profit Enterprise

Posted on by ssiconolfi

In this insightful article written by RSM Canada, the writers examine the current business environment of Not-for-Profit enterprises as it relates to talent, digital tool adoption, and operational efficiency.

Traditionally, Not-for-Profit entities have been perceived as unsophisticated offering lower wages in exchange for employees deriving value from meaningful work and societal impact.  They are often not given the appropriate level of respect for the complexity of their operations.  They are also subject to extensive scrutiny and regulations and do not lag in professionalism or complexity.

Fortunately, this perception is changing which now puts Not-for-Profit organizations in direct competition with For-profit organizations for top talent, modern business practices, and operational efficiency.

 

Read Full Article

 

TFSA: Caution with Over Contributions

Posted on by dflanagan

Taxpayers who contribute excess amounts to their TFSA are subject to a penalty tax of 1%/month that the excess contribution remains in the TFSA. If subject to the tax, an individual may apply to have the tax waived. If the individual is unsuccessful after the CRA’s first and second review of the application, the individual may apply for a judicial review of the denial in the Federal Court.

Moving Funds between TFSA Accounts

In an April 9, 2024, French Federal Court case, the taxpayer withdrew $40,000 from a TFSA at one financial institution and deposited it into another TFSA at a different financial institution at a time when he only had a TFSA contribution room of $6,270, leading to an overcontribution. Withdrawals from a TFSA are only added to an individual’s contribution room at the start of the following year. Had the taxpayer directly transferred $40,000 between the two TFSAs, there would have been no overcontribution. CRA held that the overcontributions were not the result of a reasonable error, so they could not waive the penalty tax.

The Court noted past cases that supported CRA’s interpretation that neither ignorance of the tax law nor bad advice constitutes a reasonable error. The taxpayer’s failure to transfer funds by direct transfer between the two TFSA issuers resulted in the penalty tax being properly applied CRA’s decision to deny relief was reasonable, and the application for judicial review was dismissed.

Relying On CRA Portals

In a March 27, 2024, Federal Court case, the taxpayer made TFSA contributions in line with the available TFSA room listed on CRA’s My Account; however, the balances online did not reflect some contributions, resulting in the taxpayer making excess contributions. CRA alerted the individual after the excess contributions were made. As the individual continued to contribute based on the values posted on My Account, the Court found CRA’s decision to deny relief on the penalty tax reasonable.

Do not overcontribute to your TFSA, as the penalty tax can become costly and difficult to pay. Balances posted in My Account may not be timely nor accurate.

It’s Not Too Late to Optimize Your Real Estate Structures for EIFEL

Posted on by RSM US LLP
Executive summary

Middle market real estate taxpayers should assess the impact of EIFEL rules on their investment structures to avoid denied interest expenses or penalties. Areas of focus may be the use of partnerships in real estate development or investment, non-residents with Canadian real estate, and sector-specific exemptions.

 

Middle market taxpayers in the real estate (RE) sector will need to understand the impact of Excessive Interest and Financing Expense Limitation (EIFEL) rules on their investment or development structures. Failing to model the outcome of EIFEL could lead to diminished returns on investment in the form of denied interest expenses, or penalties under the Act for non-compliance.

The key focal points of EIFEL for taxpayers operating in the RE sector should be the impact of EIFEL on partnerships, non-residents with Canadian real estate, and targeted EIFEL exemptions that are tied to the RE sector.

What are the EIFEL rules?

Initially introduced in Budget 2021, EIFEL rules are now effective for tax years of corporations and trusts starting on or after October 1, 2023. Broadly, EIFEL aims to restrict a taxpayer’s deduction for interest and financing expenses (IFE), net of interest and financing revenues (IFR), to a fixed ratio of earnings before interest, taxes, depreciation, and amortization (EBITDA), referred to in the Income Tax Act (Act) as adjusted taxable income (ATI). This fixed ratio is 30% of ATI, subject to a 40% ratio that applies for tax years that began after September 30th and before January 1, 2024.

EIFEL and Partnership Structures

Partnership structures are commonly used in RE investment or development due to their flexibility in structuring agreements, ease of resource pooling, and flow-through treatment of income, expenses, and certain tax credits. While EIFEL does not apply directly to partnerships, partners that are in scope of the rules will need to communicate and model the application of EIFEL, particularly where a partnership or its members will be leveraged with debt to facilitate RE activities.

A partnership is not a taxpayer for the purpose of EIFEL. Instead, the IFE and IFR of a partnership are attributed to partners who are corporations or trusts. The share of partnership IFE and IFR is based on the taxpayer’s share of each source of income or loss of the partnership. Where a partner determines that it will have a denied percentage of IFE, this will generally be applied to their share of IFE from a partnership and cause an income inclusion at the partner level in the amount denied (similar to the operation of thin-capitalization rules). The partnership itself will not suffer EIFEL consequences. Further, in respect to sharing IFE, certain members of a partnership may be subject to ‘at risk’ rules, which generally limit deductions to the extent a partner has invested into the partnership or earned income from the partnership. The amounts that are not included in a non-capital loss of a taxpayer because of the ‘at risk’ rules will be excluded from a partner’s EIFEL computation.

Most mitigation strategies for EIFEL will be considered at the taxpayer level, that is, the corporation or trust that is a member of a partnership. However, an election can be filed to exclude debt or lease financing amounts from the computation of EIFEL, if the debt or financing arrangement is between members of the same group for the purpose of EIFEL (generally, related or affiliated within the meaning of the Act). When a partnership is a payer or payee in these circumstances, the rules permit partnerships and their members to benefit from this election to effectively exclude a lending or lease financing arrangement from the scope of EIFEL. However, this election requires that all members of the partnership are part of the same EIFEL group as the lender or borrower, or for a partnership counterparty, each member of the lender or borrower. Additionally, all member of the partnership must be taxable Canadian corporations or a partnership which in turn is only made up of taxable Canadian corporations.

Non-residents with Real Property in Canada

Canadian residents paying rent to non-resident real property owners must withhold 25% of the payment and remit it to the CRA. Without further action, this becomes the non-resident’s final tax liability in Canada in respect to that payment. The Act allows non-resident owners of Canadian real estate to be taxed on net rental income rather than gross income if they file a section 216 return for the relevant year. The non-resident and payer can also elect for the payer to withhold on a net basis based on projected expenses, which may have cash-flow benefits for the non-resident.

For US-resident corporations or trusts that have real property in Canada and file under section 216 to be taxed on a net basis, the main exclusions from the EIFEL rules may not apply. Non-resident corporations earning income from property in Canada do not qualify. This means that section 216 filers with IFE will need to track EIFEL balances yearly to determine IFE that is denied, or available carryforward deduction capacity under EIFEL. For US middle market taxpayers that have Canadian property portfolios that are leveraged with debt, it will be important to model the application of EIFEL and explore mitigation strategies.

Multi-family and P3 Exemptions

Entities subject to EIFEL rules can exclude certain IFE amounts related to the RE sector from the IFE denial calculation. For investment funds with significant RE holdings, the benefits of relying on these exemptions are compounded. Presently, the relevant exemption is for third party IFE that is incurred in the context of public-private partnership (P3) infrastructure projects. Generally, corporations, trusts, and partnerships that act as borrowers while developing property that is owned by a public sector authority (PSA) can access this exemption, if the PSA is reasonably considered to bear these expenses.

Additionally, a focal point of Canada’s Budget 2024 was housing affordability. The government proposed a new EIFEL exemption applicable to the RE sector that is poised to be available until January 1, 2036. Taxpayers will be entitled to elect to exclude arm’s length interest from their EIFEL computation related to building or acquiring new purpose-built rental housing. This exemption is not yet passed into law but should represent welcome relief for RE developers of multi-family homes in Canada.

EIFEL for Real Estate

Middle market taxpayers in the RE sector should proactively assess and model the impact of the EIFEL rules on their investment or development structures. Of particular significance to RE developments are the impact of EIFEL on partnership structures, non-residents with Canadian real estate, and targeted exemptions that are tied to the RE sector.

This article was written by Simon Townsend, Mamtha Shree, Neil Chander, Nicole Lechter and originally appeared on 2024-09-16. Reprinted with permission from RSM Canada LLP.
© 2024 RSM Canada LLP. All rights reserved. https://rsmcanada.com/insights/tax-alerts/2024/optimize-your-real-estate-structures-for-eifel.html

RSM Canada LLP is a limited liability partnership that provides public accounting services and is the Canadian member firm of RSM International, a global network of independent assurance, tax and consulting firms. RSM Canada Consulting LP is a limited partnership that provides consulting services and is an affiliate of RSM US LLP, a member firm of RSM International. The member firms of RSM International collaborate to provide services to global clients but are separate and distinct legal entities that cannot obligate each other. Each member firm is responsible only for its own acts and omissions, and not those of any other party. Visit rsmcanada.com/about for more information regarding RSM Canada and RSM International.

The information contained herein is general in nature and based on authorities that are subject to change. RSM Canada LLP guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. RSM Canada LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein. This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer.