PMAC responded to the Department of Finance’s consultation about proposed amendments to Canada’s Income Tax Act regarding enhanced reporting requirements for trust reporting and the proposed excessive interest and financing expense limitation (EIFEL) rules.
PMAC welcomes the additional clarity to the enhanced trust beneficiary reporting requirements provided by the Department of Finance’s proposed amendments released on August 12, 2024 and supports the Department’s proposal to include certain specific exemptions from the enhanced trust reporting requirements. However, we believe that there are other items that require further clarification, and that certain additional types of trusts should be explicitly excluded from the enhanced reporting requirements, including pooled funds and certain accounts that cease to be TFSAs or FHSAs.
PMAC also supports adjusting the EIFEL rules and believes further changes can be made to avoid what may be unintended consequences of those rules, without detracting from the base erosion and profit shifting concerns underlying the EIFEL regime.
Read the full submission here.
