DFK Tax Digest
2025 Issue Two
May 30, 2025
In this DFK Tax Digest – 2025 Issue Two:
- Understanding Opportunities and Risks in the GST/HST Public Service Bodies’ Rebate – This article is intended to highlight some of the opportunities and risks associated with the public service bodies’ rebate. It focusses on more nuanced elements that are not as widely known but are nevertheless critical for maximizing the benefit and ensuring compliance…
- The “Canadian Snowbird Act” (2025, U.S. House of Representatives) – The “Canadian Snowbird Act” is *proposed* law (not enacted to date). Whether or not it is passed into law remains to be seen. Various versions of this bill have been brought forward in the last 10 years. So why pay attention to the 2025 version? Is it any more likely to be passed into law?…
- Don’t Let 74.4(2) Plan Your Trust – Generally, the purpose of this provision in the Trust Agreement is to protect against the attribution rules of subsection 74.4(2) applying (deemed interest benefit and double taxation). On the surface, it’s understandable. The rules can be quite punitive and impair the benefits the Trust was set up to provide in the first place. Unfortunately, at best, it acts as a blunt instrument that prioritizes a specific attribution rule above the…