introduction of a “Productivity Super-Deduction”, a collection of measures including some previously announced, to allow for accelerated deduction of capital investments;
broadening of the current anti-avoidance rule in respect of the 21-year deemed disposition for trusts;
proposals to limit the deferral of refundable tax on investment income through tiered corporate structures with staggered year ends;
changes in how multinational enterprises must analyze cross-border transactions between non-arm’s length persons for purposes of the transfer pricing rules;
proposals to clarify that income derived from assets held by a foreign affiliate of a Canadian insurance company that support Canadian insurance risks is taxable in Canada;
elimination of the Underused Housing Tax; and
a new reverse charge mechanism to combat “carousel fraud” under the Goods and Services Tax/Harmonized Sales Tax (“GST/HST”), starting with the telecommunications sector.