Wednesday, December 7, 2011
Friday, November 25, 2011
Withholding tax rates around the world
Chart legend:
Interest - applicable to interest income from:
Trust - applicable to mutual funds distribution, segregated fund income allocation and employee profit sharing plan trust income
Lump Sum Pension - applicable to lump sum withdrawal from:
Foreign Income - applicable to foreign non business income and foreign interest from non registered foreign outside SPIO only
For payments from Canada:
1 Argentina: Dividends are taxed at 10% if the beneficial owner is a company which holds directly at least 25% of the capital of the company paying the dividend; 15% in all other cases.
2 Brazil: Pension and periodic annuity payments - the first $4,000 paid in a calendar year is exempt.
3 Bulgaria: Dividends - for a non-resident owned investment corporation resident in Canada, withholding tax is at the rate of 10% if the beneficial owner is a company which controls directly or indirectly at least 10% of the voting power in the company paying the dividends.
4 Chile: Dividends - if the beneficial owner is a company that controls directly or indirectly at least 25% of the voting power in the company paying the dividends, withholding is at 10%; otherwise withholding is at 15%.
5 China: Dividends - if the beneficial owner is a company that controls directly or indirectly at least 10% of the voting power in the company paying the dividends, withholding is at 10%; otherwise withholding is at 15%.
6 Croatia: For pension payments, the first $12,000 CDN or equivalent in Croatian currency is exempt from tax.
7 Cyprus: Pension payments are only taxed on the excess of the basic amount of $10,000.
8 Iceland: Pension payments are only taxable in Iceland provided the total amount of pension paid in the year does not exceed $24,000 CDN or equivalent in Icelandic krones.
9 Italy: For pensions, nil if the amount is less than $10,000.
10 Netherlands: Income from a Trust is exempt from withholding tax if it is derived from sources outside the country in which the trust is resident.
11 New Zealand: Pensions are taxable on the full amount only when payment exceeds $10,000.
12 Philippines: Periodic pension payments arising in the Philippines are taxed at 30% on the amount in excess of $5,000.
13 Portugal: For periodic pension payments, tax is 15% of the amount in excess of $12,000 CDN or eqivalent Portuguese currency.
14 USA: Income from a Trust is exempt from withholding tax if it is derived from sources outside the country in which the trust is resident.
Under Article XVIII, Paragraph 3, the term "pensions" includes amounts paid under a sickness, accident or disability plan.
Interest - applicable to interest income from:
- non-registered GICs (include MVA)
- non-registered life insurance policies:
- Dividends on Deposit,
- Withdrawable Premium Fund (WPF) /Overflow Fund,
- Delayed Claim Interest
- non-registered deferred annuities
- Delayed Claim Interest (i.e. GIAs and AAs)
- Interest from Date of death to date of settlement for death claims
- non-registered Payout Annuities
- Delayed Claim Interest
- RRIF
- Interest from date of death to date of settlement for death claims
Trust - applicable to mutual funds distribution, segregated fund income allocation and employee profit sharing plan trust income
Lump Sum Pension - applicable to lump sum withdrawal from:
- RPP
- DPSP
- RRSP
- RRIF (amounts greater than 2 x minimum or 10% of value @ Jan 1)
- withdrawal of commuted value from registered payout annuity at death
- RPP - scheduled payments
- DPSP - scheduled payments
- RRIF - 2 x minimum or 10% of value @ Jan 1, whichever is greater
- Payout Annuities - RPP, DPSP, RRSP scheduled payments
- non-registered AA/IA if the annuitant was a non-resident at issue
- non-registered payout annuity - commuted value
Foreign Income - applicable to foreign non business income and foreign interest from non registered foreign outside SPIO only
For payments from Canada:
| Country | Treaty? | Interest | Dividend | Trust | Lump Sum Pension | Periodic Pension | Lump Sum Annuity | Periodic Annuity | Income Averaging Annuity Contract | Foreign Income |
| Algeria | Y | 15 | 15 | 25 | 25 | 15 | 25 | 15 | 15 | 25 |
| Argentina | Y | 12.5 | 15(1) | 25 | 25 | 15 | 25 | 15 | 15 | 25 |
| Armenia | Y | 10 | 15 | 25 | 25 | 15 | 25 | 15 | 15 | |
| Australia | Y | 10 | 15 | 15 | 15 | 15 | 15 | 15 | 25 | 25 |
| Austria | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Azerbarjian | Y | 10 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | |
| Bahamas | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Bahrain | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Bangladesh | Y | 15 | 15 | 25 | 25 | 15 | 25 | 15 | 25 | 25 |
| Barbados | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Belgium | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Belize / Leeward / Windward Islands | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Bermuda | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Brazil | Y | 15 | 25 | 25 | nil/25(2) | nil/25(2) | nil/25(2) | nil/25(2) | nil/25(2) | 25 |
| British Virgin Islands | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Bulgaria | Y | 10 | 15(3) | 15 | 25 | 15 | 25 | 10 | 10 | 25 |
| Country | Treaty? | Interest | Dividend | Trust | Lump Sum Pension | Periodic Pension | Lump Sum Annuity | Periodic Annuity | IAAC | Foreign Income |
| Cameroon | Y | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Cayman Islands | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Chile | Y | 15 | 15 (4) | 15 | 25 | 25 | 25 | 15 | 15 | 25 |
| China | Y | 10 | 15 (5) | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Columbia | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Common Wealth of Ind States | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Costa Rica | TBD | |||||||||
| Republic of Croatia | Y | 10 | 15 | 15 | 25 | nil/15 (6) | 25 | 10 | 10 | 25 |
| Cuba | TBD | |||||||||
| Cyprus | Y | 15 | 15 | 15 | 25 | nil/15 (7) | 25 | 15 | 25 | 25 |
| Czech Republic | Y | 10 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
| Denmark | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Dominican Republic | Y | 18 | 18 | 18 | 25 | 18 | 25 | 18 | 25 | 25 |
| Country | Treaty? | Interest | Dividend | Trust | Lump Sum Pension | Periodic Pension | Lump Sum Annuity | Periodic Annuity | IAAC | Foreign Income |
| Ecuador | Y | 15 | 15 | 15 | 25 | 15 (on amounts over $12,000) | 25 | 15 | 15 | 25 |
| Egypt | Y | 15 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Estonia | Y | 10 | 15 | 15 | 25 | 15 | 25 | 10 | 10 | 25 |
| Finland | Y | 10 | 15 | 15 | 25 | 20 | 25 | 15 | 25 | 25 |
| France | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Gabon | Y | 10 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Germany | Y | 10 | 15 | 25 | 25 | 15 | 25 | 25 | 25 | 25 |
| Greece | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Grenada | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Guyana | Y | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Holland (see Netherlands) | ||||||||||
| Hong Kong | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Hungary | Y | 10 | 15 | 15 | 25 | 15 | 25 | 10 | 10 | 25 |
| Iceland | Y | 10 | 15 | 15 | 25 | 15 (8) | 25 (8) | 15 | 15 | 25 |
| India | Y | 15 | 25 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Indonesia | Y | 10 | 15 | 25 | 25 | 15 | 25 | 15 | 25 | 25 |
| Ireland | Y | 15 | 15 | 15 | 15 | 15 | 15 | 15 | nil | 25 |
| Israel | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Italy | Y | 15 | 15 | 25 | 25 | 15 (9) | 25 (9) | 25 | 25 | 25 |
| Ivory Coast | Y | 15 | 15 | 25 | 25 | 15 | 25 | 15 | 15 | 25 |
| Country | Treaty? | Interest | Dividend | Trust | Lump Sum Pension | Periodic Pension | Lump Sum Annuity | Periodic Annuity | IAAC | Foreign Income |
| Jamaica | Y | 15 | 15 | 15 | 25 | 25 | 25 | 15 | 25 | 25 |
| Japan | Y | 10 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Jordan | Y | 10 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Kazakhastan | Y | 10 | 15 | 25 | 25 | 15 | 25 | 25 | 25 | 25 |
| Kenya | Y | 15 | 25 | 25 | 25 | 15 | 25 | 15 | 25 | 25 |
| Korea (South) | Y | 10 | 15 | 25 | 25 | 15 | 25 | 10 | 25 | 25 |
| Kuwait | Y | 10 | 15 | 25 | 25 | 15 | 25 | 15 | 25 | 25 |
| Kyrgyzstan | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
| Latvia | Y | 10 | 15 | 15 | 25 | 15 | 25 | 10 | 10 | 25 |
| Lebanon | Y | 10 | 15 | 25 | 25 | 15 | 25 | 25 | 25 | 25 |
| Liberia | Y | 20 | 15 | 20 | 25 | 25 | 25 | 20 | 25 | 25 |
| Liechtenstein | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Lithuania | Y | 10 | 15 | 15 | 25 | 15 | 25 | 10 | 10 | 25 |
| Luxembourg | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Country | Treaty? | Interest | Dividend | Trust | Lump Sum Pension | Periodic Pension | Lump Sum Annuity | Periodic Annuity | IAAC | Foreign Income |
| Malaysia | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Malta | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Mexico | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
| Moldova | Y | 10 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
| Mongolia | Y | 10 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
| Morocco | Y | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Netherlands | Y | 10 | 15 | 15 (10) | 25 | 15 | 25 | 15 | 15 | 25 |
| Netherlands Antilles | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| New Zealand | Y | 15 | 15 | 15 | 15 | 15 (11) | 25 (11) | 15 | 25 | 25 |
| Nigeria | Y | 12.5 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Norway | Y | 10 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
| Oman | Y | 10 | 15 | 25 | 25 | 15 | 25 | 15 | 15 | |
| Pakistan | Y | 15 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Panama | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Papua New Guinea | Y | 10 | 15 | 25 | 25 | 15 | 25 | 15 | 25 | 25 |
| Peru | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
| Philippines | Y | 15 | 15 | 25 | 25 | 25 (12) | 25 | 25 | 25 | 25 |
| Country | Treaty? | Interest | Dividend | Trust | Lump Sum Pension | Periodic Pension | Lump Sum Annuity | Periodic Annuity | IAAC | Foreign Income |
| Poland | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Portugal | Y | 10 | 15 | 15 | 25 | nil/15 (13) | 25 | 15 | 15 | 25 |
| Puerto Rico | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Romania | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Russia | Y | 10 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Saudi Arabia | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Senegal | Y | 15 | 15 | 15 | 25 | 15% (on amounts over $12,000) | 25 | 15 | 15 | 25 |
| Seychelles | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Sierra Leone | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Singapore | Y | 15 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Slovak Republic | Y | 10 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
| Slovenia | Y | 10 | 15 | 15 | 25 | 15 | 25 | 10 | 10 | 25 |
| South Africa | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Spain | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Sri Lanka | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Country | Treaty? | Interest | Dividend | Trust | Lump Sum Pension | Periodic Pension | Lump Sum Annuity | Periodic Annuity | IAAC | Foreign Income |
| Sweden | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Switzerland | Y | 10 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Taiwan | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Tanzania | Y | 15 | 25 | 25 | 25 | 15 | 25 | 15 | 15 | 25 |
| Thailand | Y | 15 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Trinidad / Tobago | Y | 10 | 15 | 25 | 25 | 15 | 25 | 25 | 25 | 25 |
| Tunisia | Y | 15 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| Turkey | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Ukraine | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| United Arab Emirates | Y | 10 | 15 | 15 | 25 | 25 | 25 | 25 | 25 | 25 |
| United Kingdom | Y | 10 | 15 | 15 | 25 | nil | 25 | 10 | 25 | 25 |
| Uruguay | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Country | Treaty? | Interest | Dividend | Trust | Lump Sum Pension | Periodic Pension | Lump Sum Annuity | Periodic Annuity | IAAC | Foreign Income |
| USA | Y | 10 | 15 | 15 (14) | 25 | 15 (14) | 25 | 15 | 25 | 25 |
| Uzbekistan | Y | 10 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Vietnam | Y | 10 | 15 | 15 | 25 | 15 | 25 | 25 | 25 | 25 |
| Venezuela | Y | 10 | 15 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Virgin Islands (US) | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Yugoslavia | N | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 | 25 |
| Zambia | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 25 | 25 |
| Zimbabwe | Y | 15 | 15 | 15 | 25 | 15 | 25 | 15 | 15 | 25 |
2 Brazil: Pension and periodic annuity payments - the first $4,000 paid in a calendar year is exempt.
3 Bulgaria: Dividends - for a non-resident owned investment corporation resident in Canada, withholding tax is at the rate of 10% if the beneficial owner is a company which controls directly or indirectly at least 10% of the voting power in the company paying the dividends.
4 Chile: Dividends - if the beneficial owner is a company that controls directly or indirectly at least 25% of the voting power in the company paying the dividends, withholding is at 10%; otherwise withholding is at 15%.
5 China: Dividends - if the beneficial owner is a company that controls directly or indirectly at least 10% of the voting power in the company paying the dividends, withholding is at 10%; otherwise withholding is at 15%.
6 Croatia: For pension payments, the first $12,000 CDN or equivalent in Croatian currency is exempt from tax.
7 Cyprus: Pension payments are only taxed on the excess of the basic amount of $10,000.
8 Iceland: Pension payments are only taxable in Iceland provided the total amount of pension paid in the year does not exceed $24,000 CDN or equivalent in Icelandic krones.
9 Italy: For pensions, nil if the amount is less than $10,000.
10 Netherlands: Income from a Trust is exempt from withholding tax if it is derived from sources outside the country in which the trust is resident.
11 New Zealand: Pensions are taxable on the full amount only when payment exceeds $10,000.
12 Philippines: Periodic pension payments arising in the Philippines are taxed at 30% on the amount in excess of $5,000.
13 Portugal: For periodic pension payments, tax is 15% of the amount in excess of $12,000 CDN or eqivalent Portuguese currency.
14 USA: Income from a Trust is exempt from withholding tax if it is derived from sources outside the country in which the trust is resident.
Under Article XVIII, Paragraph 3, the term "pensions" includes amounts paid under a sickness, accident or disability plan.
Published: 04/12/2009
Thursday, November 24, 2011
October 2011: Monthly Indicator Recap
| HOUSING INDICATORS* | DIRECTION | % CHANGE (vs. last month) | OCTOBER LEVELS |
|---|---|---|---|
| Volume of MLS® Home Listings |  | 0.26% | 72,739 |
| Volume of MLS® Home Sales | | 1.26% | 38,819 |
| Average MLS® Sale Price (Canada) | | 0.65% | $363,504 |
| ECONOMIC INDICATORS** | DIRECTION | % CHANGE (vs. last month) | RATES |
| Unemployment Rate (October 2011) | | 0.20% | 7.30% |
| GDP (August 2011) | | 0.30% | N/A |
| Retail Sales (August 2011) | | 0.50% | N/A |
| Consumer Price Index (September 2011) | | 3.20% (Year‐o‐year, September) | N/A |
| FINANCIAL INDICATORS | DIRECTION | % CHANGE (vs. last month) | RATES |
| Prime Rate** |  | 0.00% | 3.00% |
| 5 Year Fixed Posted Mortgage Rate*** | | 0.10% | 5.29% |
*Seasonally adjusted month-to-month results; Source: The Canadian Real Estate Association
** Source: Statistics Canada
*** Source: RBC
Wednesday, November 23, 2011
European stress levels reaching a boiling point
Funding stress levels in the European zone are slowly inching towards an unsustainable situation as different credit markets across the continent are showing signs of faltering. The big news overnight is that Germany held a Bunde auction which could only be described as a disaster. With yields touching 2% on their 10 year note, returns were not enough to entice investors as the German Bundesbank had to purchase 39% of the offering so that the auction would not fail. While this is not the same situation as the peripheral countries, in the sense that they do not have to pay loan shark rates on their debt, it is a sign that investors would rather hoard their cash rather than being in any sort of debt security.
We are all aware the off the stress going on in the sovereign debt market but the other devil quietly lurking in the shadows is the interbank funding market. Banks primarily fund their activities through the use of the overnight market where they either borrow money if they are short or park money if they are over funded. The failure of this market is what ultimately brought down Lehman in 2008 as they were not able to fund their day to day operations. The London Interbank Overnight Rate (LIBOR) is the main rate and it has been slowly creeping since the beginning of summer. The European banks that are in better shape have significantly pulled back their operations in the overnight market while the struggling ones are in increasing need of it. This is creating a negative feedback loop where rates are continually rising and liquidity is continually falling. It is these secondary credit markets that can provide the early warning signs of a banking crisis.
The Euro has taken a beating overnight as seemingly continuous barrage of damaging news will not let the currency catch a breather. The common currency is down 3.4% on the month and 6% from its high of 1.4247 on Oct 27th. The downward trend channel is holding strong and the failure of the US debt committee couldn’t even help the Euro out. It will be up to the politicians to figure out a way to calm the market but their track record so far is not reassuring.
We are all aware the off the stress going on in the sovereign debt market but the other devil quietly lurking in the shadows is the interbank funding market. Banks primarily fund their activities through the use of the overnight market where they either borrow money if they are short or park money if they are over funded. The failure of this market is what ultimately brought down Lehman in 2008 as they were not able to fund their day to day operations. The London Interbank Overnight Rate (LIBOR) is the main rate and it has been slowly creeping since the beginning of summer. The European banks that are in better shape have significantly pulled back their operations in the overnight market while the struggling ones are in increasing need of it. This is creating a negative feedback loop where rates are continually rising and liquidity is continually falling. It is these secondary credit markets that can provide the early warning signs of a banking crisis.
The Euro has taken a beating overnight as seemingly continuous barrage of damaging news will not let the currency catch a breather. The common currency is down 3.4% on the month and 6% from its high of 1.4247 on Oct 27th. The downward trend channel is holding strong and the failure of the US debt committee couldn’t even help the Euro out. It will be up to the politicians to figure out a way to calm the market but their track record so far is not reassuring.
Saturday, November 12, 2011
Revenu Québec - Contribution Paid by the Employee to a Private Health Services Plan (Group Insurance Plan) - Tax News - Information Centre
Revenu Québec - Contribution Paid by the Employee to a Private Health Services Plan (Group Insurance Plan) - Tax News - Information Centre
November 8, 2011
Contribution Paid by the Employee to a Private Health Services Plan (Group Insurance Plan)
A tax credit for medical expenses may be claimed on the income tax return of an employee, a former employee or a retired employee who paid a contribution (or premium) to a private health services plan (group insurance plan) to cover, for example, medical or dental costs.
To indicate on an employee's RL-1 slip (RL-1) the amounts that he or she paid to such a plan, enter 235 in one of the blank boxes in the centre of the slip, followed by the amount or, in the empty space in the centre of the slip, write "Premium paid to a private health services plan" (or "Prime versée à un régime privé d'assurance maladie"), followed by the amount. This entry is optional.However, if you do not provide this information on the RL-1 slip, an employee may ask you for supporting documents. Do not include this amount in box A.
Revenu Québec - Rates, Thresholds and Amounts for 2012 Source Deductions and Contributions - Tax News - Information Centre
Revenu Québec - Rates, Thresholds and Amounts for 2012 Source Deductions and Contributions - Tax News - Information Centre
If an employee 65 or older expects to earn more than $5,000 in eligible work income during the year, he or she may ask you to reduce applicable source deductions by completing form TP-1015.3-V.
November 9, 2011
Rates, Thresholds and Amounts for 2012 Source Deductions and Contributions
Below are the rates, thresholds and amounts applicable for 2012 source deductions and contributions.Indexation for 2012
Every year, the personal income tax system is automatically indexed. The indexation factor for 2012 is 2.66%.Income thresholds and income tax brackets
For 2012, the income tax rates applicable to the three income tax brackets remain at 16%, 20% and 24% and the thresholds for the three income tax brackets have been indexed as follows:- The 16% rate applies to taxable income of $40,100 or less. (The threshold was previously $39,060.)
- The 20% rate applies to taxable income of more than $40,100 but not more than $80,200. (The threshold was previously $78,120.)
- The 24% rate applies to taxable income of more than $80,200.
Source deductions return (form TP-1015.3-V)
The Source Deductions Return (form TP-1015.3-V) has been amended to take into account the new tax credit for workers 65 or older. In addition, the amounts on form TP-1015.3-V have been indexed.Amount for workers 65 or older
A new tax credit for workers 65 or older will gradually be introduced beginning January 1, 2012. This new tax credit is designed to eliminate the income tax that such workers would normally have to pay on a portion of their eligible work income that is in excess of $5,000. The primary work income targeted by the measure is employment income.If an employee 65 or older expects to earn more than $5,000 in eligible work income during the year, he or she may ask you to reduce applicable source deductions by completing form TP-1015.3-V.
If you use Table TP-1015.TI-V
If you use Table TP-1015.TI-V to calculate source deductions, you are not required to make any adjustments since the amount of this tax credit is included in the amounts used to establish the deduction codes in Table TP-1015.TI-V. As of 2012, these codes will take into account the tax credit for workers 65 or older.If you use the formulas
If you calculate source deductions using the formulas in the guide Formulas to Calculate Source Deductions and Contributions (TP-1015.F-V), changes have been made to take the new tax credit into account. For more information on the changes, see Part 2 of the guide.Indexation of the amounts in form TP-1015.3-V
| | 2012 | 2011 |
|---|---|---|
| Basic amount | $10,925 | $10,640 |
| Amount transferred from one spouse to the other | $10,925 | $10,640 |
| Amount for other dependents who are 18 or over | $2,930 | $2,855 |
| Amount for a child under 18 enrolled in post-secondary studies | $2,015 | $1,965 |
| Additional amount for a person living alone (single-parent family) | $1,585 | $1,545 |
| Amount for a severe and prolonged impairment in mental or physical functions | $2,485 | $2,420 |
| Amount for a person living alone | $1,280 | $1,245 |
| Age amount | $2,350 | $2,290 |
| Amount for retirement income | $2,090 | $2,035 |
| Reduction threshold used to calculate net family income (This income is used to calculate the age amount, the amount for a person living alone and the amount for retirement income.) | $31,695 | $30,875 |
Bonuses and retroactive pay
The threshold that determines the method to be used to calculate the income tax withholding from bonuses and retroactive pay has been increased from $13,300 to $13,700 for 2012.Maximum deduction for employment income
The maximum deduction for employment income has been increased from $1,045 to $1,075 for 2012.If you are using Table TP-1015.TI-V
The table takes into account the increase in the deduction in calculating the remuneration subject to source deductions of income tax.If you are using the formulas
If you are using the formulas in the guide Formulas to Calculate Source Deductions and Contributions (TP-1015.F-V) to calculate source deductions, changes have been made to take into account the increase in the maximum deduction for employment income.Amount paid to an emergency services volunteer
The tax-exempt amount of financial compensation paid to an emergency services volunteer has been increased from $1,045 to $1,075 for 2012.Maximum pensionable earnings and contribution rate (QPP)
The QPP contribution rate has been increased from 9.9% to 10.05% for 2012, which corresponds to a contribution rate of 5.025% for the employee and 5.025% for the employer. In addition, the maximum pensionable earnings for the purposes of the QPP have been increased from $48,300 to $50,100. The maximum annual contribution to be withheld for any employee has therefore been increased from $2,217.60 to $2,341.65.Maximum insurable earnings and premium rate (QPIP)
The maximum insurable earnings subject to QPIP premiums have been increased from $64,000 to $66,000 for 2012. Also, the employee premium rate has been increased from 0.537% to 0.559%, and the employer premium rate has been increased from 0.752% to 0.782%. As a result, the maximum employee premium is $368.94 (instead of $343.68) and that of the employer is $516.12 (instead of $481.28).Maximum remuneration subject to the contribution to the financing of the CNT
The portion of the remuneration that exceeded $66,000 (instead of $64,000) is not subject to the contribution to the financing of the CNT for 2012.Monday, November 7, 2011
Triple dip ahead for U.S. home prices
Fiserv said home values will fall 3.6% by next June in the U.S., which will be a new low from the 2006 peak, down 35% from that point.
CNN Money reports the company’s 2012 prediction might not even be the eventual bottom, due to the massive shadow inventory of foreclosures that has yet to even be released.
Some U.S. cities popular with Canadians are among those expected to be hardest hit with price decreases next year. Naples, Fla., for example, will see prices drop another 18.9% by next June, according to Fiserv. That’s the largest decrease in price of any metro area covered.
Las Vegas wasn’t far behind, expected to see prices fall 15.9%, followed by Riverside, Calif., predicted to fall another 14.8%, and Miami was projected with a 14.8% drop, according to CNN.
But other cities, already hard hit in years past, will see some kind of recovery by next year in prices. Oscala, Fla., for example, will see prices gain 22.4% for the 12 months ending June 30, 2012. CNN said Oscala had already seen home prices drop about 50% previously.
Similarly, other previously suffering markets will gain next year, like Napa, Calif., projected to rise 20.9% next year, and Panama City, Fla., expected to gain 18.2%.
The U.S. home market will hit another low by next year, dropping even further below its 2006 peak, according to Fiserv, a financial analytics company.
Fiserv said home values will fall 3.6% by next June in the U.S., which will be a new low from the 2006 peak, down 35% from that point.
CNN Money reports the company’s 2012 prediction might not even be the eventual bottom, due to the massive shadow inventory of foreclosures that has yet to even be released.
Some U.S. cities popular with Canadians are among those expected to be hardest hit with price decreases next year. Naples, Fla., for example, will see prices drop another 18.9% by next June, according to Fiserv. That’s the largest decrease in price of any metro area covered.
Las Vegas wasn’t far behind, expected to see prices fall 15.9%, followed by Riverside, Calif., predicted to fall another 14.8%, and Miami was projected with a 14.8% drop, according to CNN.
But other cities, already hard hit in years past, will see some kind of recovery by next year in prices. Oscala, Fla., for example, will see prices gain 22.4% for the 12 months ending June 30, 2012. CNN said Oscala had already seen home prices drop about 50% previously.
Similarly, other previously suffering markets will gain next year, like Napa, Calif., projected to rise 20.9% next year, and Panama City, Fla., expected to gain 18.2%.
 QST HarmonizationRecently, the governments of Canada and Quebec announced the signing of a memorandum of agreement (MOA) to harmonize the Quebec sales tax (QST) and the federal goods and services tax (GST) effective January 1, 2013. The impact of harmonization and some of the transitional issues are expected to be different from those associated with the HST in Ontario. (As a result of last summer's referendum, British Columbia is expected to revert to its PST on April 1, 2013.)As of January 1, 2012, the rate under the current QST regime will be 9.5 percent, applied to the selling price plus GST. Effective January 1, 2013, the rate of the new "amended QST" will be 9.975 percent applied to the selling price excluding GST. The change is approximately revenue-neutral. The QST is already partially harmonized and it is expected that the tax base of the amended QST and the GST will continue to be largely the same, although financial services will become exempt and the current QST exemptions (for example, the exemption for books and for infants' diapers) will be maintained. Interestingly, Quebec will retain its separate legislation (An Act Respecting the Québec Sales Tax) and, as a result, will administer the amended QST rather than an HST levied under the federal Excise Tax Act (as is the case in the other harmonized provinces). Revenu Québec (not the CRA) will continue to administer both the GST and the amended QST; therefore, businesses will be required to prepare separate returns under the amended QST and will be subject to audits by Revenu Québec. Financial services are currently zero-rated for QST purposes, whereas the GST/HST system treats such services as exempt. As part of harmonization, financial services will become exempt. Although there will be no impact on consumers purchasing financial services (since zero-rated services are taxed at 0 percent), financial institutions will no longer be able to claim input tax refunds (ITRs), the Quebec equivalent of input tax credits, for the QST paid on their inputs relating to the supply of exempt financial services. However, the compensatory tax that was established to partly compensate for the ITRs that financial institutions were receiving will be eliminated over time. Overall, the financial services sector will experience a significant tax increase. Large businesses (those with taxable sales exceeding $10 million) will gain, in that they will eventually be able to claim full ITRs on all inputs. Currently, the QST system allows ITRs for most inputs but not for certain goods and services (for example, specified road vehicles, energy, telecommunications, and meals and entertainment) acquired by large businesses. As a result of the harmonization, ITRs for the QST paid by large businesses on all inputs will be allowed gradually over a period of three years, beginning in 2018. One interesting question is the extent to which the requirements for the amended QST can apply to non-residents, given that the requirements are under provincial legislation. Under section 92 of the Constitution Act, 1867, the provinces' legislative authority is limited to direct taxation "within the province" and to property and civil rights "in the province." In contrast, the provincial component of the HST and the collection requirements are imposed under federal legislation, and so are not similarly restricted. Draft legislation, transitional measures, and additional details are expected to be announced by June 1, 2012. Jung Ah Kwon, Michael Tsao, and Simon Thang KPMG LLP, Toronto jkwon1@kpmg.ca, mtsao@kpmg.ca, and sthang@kpmg.ca | |
| Canadian Tax Focus Volume 1, Number 3, November 2011 ©2011, Canadian Tax Foundation |
| |||||
Tuesday, October 4, 2011
Prescribed Information To Support ITCs
An ITC claim must be supported by information prescribed in subsection 164(4) of the Excise Tax Act and in the Input Tax Credit Information (GST/HST) Regulations. The TCC in Les Pro-Poseurs Inc. (2011 TCC 113) recently considered whether invoices provided by the taxpayer to support its ITCs met the information requirements. The decision reconfirms that the ETA's and the regulations' information requirements are mandatory, not directory, and that compliance is compulsory if one wishes to claim ITCs.
In Les Pro-Poseurs, the appellant was a construction contractor that subcontracted out its work overflow. For the relevant period, the CRA rejected the appellant's claims for ITCs related to supplies of property and services purportedly acquired from a number of "dubious" suppliers (the subcontractors). The appellant appealed to the TCC.
The minister submitted that the invoices provided by the appellant to support its ITCs failed to meet the information requirements because they did not contain sufficient information to allow identification of the alleged supplies and determination of the ITC amount. The minister found that the subcontractors did not have staff or equipment to make the alleged supplies, some of them were untraceable, and some were in default to Revenu Québec with respect to several tax statutes. On the basis of those findings, the minister further submitted that the invoices were false because the subcontractors could not have provided the supplies to the appellant. Furthermore, because the subcontractors cashed most of their cheques from the appellant at cheque-cashing businesses, which charged an "astronomical commission," the minister suggested that the invoices in question were invoices "of convenience," having been prepared merely in order to allow the appellant to inappropriately claim ITCs.
At the TCC, the appellant submitted that the minister erred in concluding that the invoices were fictitious on the basis of his profile of the subcontractors and that, on the evidence, the appellant had established a prima facie case that the subcontractors actually provided it with the supplies. Although some of the prescribed information did not appear on the invoices, the appellant said that those strict requirements should not be imposed because most of the construction workers involved did not have "a gift for writing" and that the supporting documents met the industry standard.
The main issue before the TCC was whether the appellant was entitled to the ITCs claimed. The court first considered whether the appellant actually acquired the supplies from the subcontractors; it drew a negative inference from the fact that the appellant did not call witnesses (such as the subcontractors' officers and employees) who could have testified in support of the appellant's position. In determining whether the appellant's evidence made out a prima facie case that demolished the minister's assumptions in making the assessment, the TCC concluded that the testimony of the appellant's witnesses was either deficient or not credible in establishing that the subcontractors actually made the supplies to the appellant.
The TCC then considered whether the invoices provided by the subcontractors met the information requirements. The court concurred with its earlier views in Key Property Management Corporation (2004 TCC 210) and Davis (2004 TCC 662) to the effect that the legislative and regulatory requirements were mandatory and must be strictly enforced: the whole purpose of the provisions was (as stated in Key Property) "to protect the consolidated revenue fund against both fraudulent and innocent incursions." The court said that the invoices provided by the subcontractors did not meet the information requirements because they did not contain the information necessary to allow the minister to identify the work carried out by the subcontractors. Because the evidence weighed against the appellant, the TCC concluded that the appellant could not claim the ITCs related to those invoices issued by the subcontractors.
The courts have set a very high bar for anyone attempting to get around the mandatory information requirements for ITC claiMs. The TCC in Pro-Poseurs stressed that "[i]t is for the Court and not the industry to determine what the legislator means by 'description of each supply sufficient to identify it.'" The decision is a red flag for all businesses: to perfect an ITC claim, the best prescription is to ensure that each invoice issued by a supplier contains all the prescribed information.
Robert G. Kreklewetz and Jenny Siu
Millar Kreklewetz LLP, Toronto
In Les Pro-Poseurs, the appellant was a construction contractor that subcontracted out its work overflow. For the relevant period, the CRA rejected the appellant's claims for ITCs related to supplies of property and services purportedly acquired from a number of "dubious" suppliers (the subcontractors). The appellant appealed to the TCC.
The minister submitted that the invoices provided by the appellant to support its ITCs failed to meet the information requirements because they did not contain sufficient information to allow identification of the alleged supplies and determination of the ITC amount. The minister found that the subcontractors did not have staff or equipment to make the alleged supplies, some of them were untraceable, and some were in default to Revenu Québec with respect to several tax statutes. On the basis of those findings, the minister further submitted that the invoices were false because the subcontractors could not have provided the supplies to the appellant. Furthermore, because the subcontractors cashed most of their cheques from the appellant at cheque-cashing businesses, which charged an "astronomical commission," the minister suggested that the invoices in question were invoices "of convenience," having been prepared merely in order to allow the appellant to inappropriately claim ITCs.
At the TCC, the appellant submitted that the minister erred in concluding that the invoices were fictitious on the basis of his profile of the subcontractors and that, on the evidence, the appellant had established a prima facie case that the subcontractors actually provided it with the supplies. Although some of the prescribed information did not appear on the invoices, the appellant said that those strict requirements should not be imposed because most of the construction workers involved did not have "a gift for writing" and that the supporting documents met the industry standard.
The main issue before the TCC was whether the appellant was entitled to the ITCs claimed. The court first considered whether the appellant actually acquired the supplies from the subcontractors; it drew a negative inference from the fact that the appellant did not call witnesses (such as the subcontractors' officers and employees) who could have testified in support of the appellant's position. In determining whether the appellant's evidence made out a prima facie case that demolished the minister's assumptions in making the assessment, the TCC concluded that the testimony of the appellant's witnesses was either deficient or not credible in establishing that the subcontractors actually made the supplies to the appellant.
The TCC then considered whether the invoices provided by the subcontractors met the information requirements. The court concurred with its earlier views in Key Property Management Corporation (2004 TCC 210) and Davis (2004 TCC 662) to the effect that the legislative and regulatory requirements were mandatory and must be strictly enforced: the whole purpose of the provisions was (as stated in Key Property) "to protect the consolidated revenue fund against both fraudulent and innocent incursions." The court said that the invoices provided by the subcontractors did not meet the information requirements because they did not contain the information necessary to allow the minister to identify the work carried out by the subcontractors. Because the evidence weighed against the appellant, the TCC concluded that the appellant could not claim the ITCs related to those invoices issued by the subcontractors.
The courts have set a very high bar for anyone attempting to get around the mandatory information requirements for ITC claiMs. The TCC in Pro-Poseurs stressed that "[i]t is for the Court and not the industry to determine what the legislator means by 'description of each supply sufficient to identify it.'" The decision is a red flag for all businesses: to perfect an ITC claim, the best prescription is to ensure that each invoice issued by a supplier contains all the prescribed information.
Robert G. Kreklewetz and Jenny Siu
Millar Kreklewetz LLP, Toronto
US Tax Collection in Canada
How far the US tax authorities' reach extends into Canada in respect of US tax liability and penalty collection depends on the status of the debtor and the nature of the debt or penalty. The following discussion relates to the collection of taxes and associated interest, foreign bank account report (FBAR) penalties, fraud penalties, penalties for failure to pay, and accuracy-related penalties, all of which obligations are imposed under the Internal Revenue Code, except for FBAR penalties, which are imposed by the Bank Secrecy Act.
The general common-law position in respect of collection of foreign tax debts is set out in United States of America v. Harden ([1963] SCR 366). The US government attempted to collect a tax debt by registering the debt as a civil debt in a Canadian court. The court concluded that by attempting to collect taxes in this manner, the United States was attempting to enforce its revenue laws in Canada, a violation of the longstanding rule that a sovereign state will not collect taxes for the benefit of a foreign state. Quoting Peter Buchanan Ld. & Machaig v. McVey, the SCC adopted the reasoning of the High Court of Ireland that "in no circumstances will the courts directly or indirectly enforce the revenue laws of another country." The court said that "[n]o court ought to undertake an inquiry which it cannot prosecute without determining whether those laws are consonant with its own notions of what is proper." There is no distinction between the underlying claim and the collection of that claim.
That common-law position of non-enforcement is altered by article XXVI A of the Canada-US treaty, which establishes authority for assistance in the collection of tax debts. This assistance is provided in respect of "revenue claims": "all categories of taxes collected" "together with interest, costs, additions to such taxes and civil penalties" and "contributions to social security and employment insurance premiums levied by or on behalf of" the US government, which includes taxes and penalties imposed under the Code. The CRA treats US taxes and penalties that fall within this description in the same way that it treats domestic debts and uses its collection tools to recover the money. Thus, US tax owing, and interest and penalties ancillary thereto, is collectible under those treaty provisions. However, the treaty contains an important exception: assistance is not provided if the individual is a Canadian citizen.
In contrast, FBAR penalties are assessed for failure to report, and they are not connected to an underlying tax debt or to any penalty under the Code. The specific enumeration of social security and employment insurance contributions in the definition of revenue claim in article XXVI A(9) makes it clear that the treaty drafters turned their minds to other types of government debts that do not fit within the general description of "all categories of taxes collected." Thus, FBAR penalties are not collectible under article XXVI A because they are not income or capital taxes or taxes imposed under the Code or related penalties. There is still potential for the competent authorities to agree to extend the meaning of "tax" to include FBAR penalties in accordance with article XXVI A(11).
The United States may pursue recourse in Canadian courts regarding the collection of FBAR penalties. With respect to a foreign penal debt, the rule is clear: Canadian courts will not enforce it (Pro Swing Inc. v. Elta Golf Inc., 2006 SCC 52). The underpinning rationale is that foreign law conflicts with and encroaches on domestic law and thus the sovereignty of the domestic state. "Penal law" is defined in United States of America v. Ivey (1995 CanLII 7241 (ONSC), aff'd. 1996 CanLII 991 (ONCA)) as "all suits in favour of the State for the recovery of pecuniary penalties for any violation of statutes for the protection of its revenue or other municipal laws, and . . . all judgments for such penalties." FBAR penalties should not be enforced because they appear prima facie to fall within that description: they serve to punish a US citizen or green-card holder for his or her failure to report to the US government. Furthermore, FBAR penalties are not compensatory and do not affect the disgorgement of profits. (See Ivey; United States Securities and Exchange Commission v. Cosby, 2000 BCSC 338; and United States of America ( SEC ) v. Shull, 1999 CanLII 6625 (BCSC).
Harden makes it clear that taxes cannot be collected pursuant to registration of a civil judgment in a reciprocal jurisdiction. Although FBAR penalties are not taxes, it is highly likely that they are penal and thus are not enforceable in Canada. However, some uncertainty exists, and it may be possible to collect FBAR penalties in Canada on the principle of comity, discussed in Morguard Investments Ltd. v. De Savoye ([1990] 3 SCR 1077): a foreign judgment for a debt may be enforced in Canada if the party brings a separate action in a Canadian court.
In summary, a Canadian citizen need have little concern about the collection of US tax, interest, and ancillary penalties. However, a US taxpayer who is a Canadian resident and not a Canadian citizen and who owes US tax, interest, and penalties may face collection thereof by the CRA pursuant to treaty article XXVI A. It is extremely unlikely that Canadian citizens or residents will have to face collection of FBAR penalties, except in the very unlikely event that those penalties may be characterized as registrable civil judgments.
Erin L. Frew and S. Natasha Reid
Thorsteinssons LLP, Vancouver
The general common-law position in respect of collection of foreign tax debts is set out in United States of America v. Harden ([1963] SCR 366). The US government attempted to collect a tax debt by registering the debt as a civil debt in a Canadian court. The court concluded that by attempting to collect taxes in this manner, the United States was attempting to enforce its revenue laws in Canada, a violation of the longstanding rule that a sovereign state will not collect taxes for the benefit of a foreign state. Quoting Peter Buchanan Ld. & Machaig v. McVey, the SCC adopted the reasoning of the High Court of Ireland that "in no circumstances will the courts directly or indirectly enforce the revenue laws of another country." The court said that "[n]o court ought to undertake an inquiry which it cannot prosecute without determining whether those laws are consonant with its own notions of what is proper." There is no distinction between the underlying claim and the collection of that claim.
That common-law position of non-enforcement is altered by article XXVI A of the Canada-US treaty, which establishes authority for assistance in the collection of tax debts. This assistance is provided in respect of "revenue claims": "all categories of taxes collected" "together with interest, costs, additions to such taxes and civil penalties" and "contributions to social security and employment insurance premiums levied by or on behalf of" the US government, which includes taxes and penalties imposed under the Code. The CRA treats US taxes and penalties that fall within this description in the same way that it treats domestic debts and uses its collection tools to recover the money. Thus, US tax owing, and interest and penalties ancillary thereto, is collectible under those treaty provisions. However, the treaty contains an important exception: assistance is not provided if the individual is a Canadian citizen.
In contrast, FBAR penalties are assessed for failure to report, and they are not connected to an underlying tax debt or to any penalty under the Code. The specific enumeration of social security and employment insurance contributions in the definition of revenue claim in article XXVI A(9) makes it clear that the treaty drafters turned their minds to other types of government debts that do not fit within the general description of "all categories of taxes collected." Thus, FBAR penalties are not collectible under article XXVI A because they are not income or capital taxes or taxes imposed under the Code or related penalties. There is still potential for the competent authorities to agree to extend the meaning of "tax" to include FBAR penalties in accordance with article XXVI A(11).
The United States may pursue recourse in Canadian courts regarding the collection of FBAR penalties. With respect to a foreign penal debt, the rule is clear: Canadian courts will not enforce it (Pro Swing Inc. v. Elta Golf Inc., 2006 SCC 52). The underpinning rationale is that foreign law conflicts with and encroaches on domestic law and thus the sovereignty of the domestic state. "Penal law" is defined in United States of America v. Ivey (1995 CanLII 7241 (ONSC), aff'd. 1996 CanLII 991 (ONCA)) as "all suits in favour of the State for the recovery of pecuniary penalties for any violation of statutes for the protection of its revenue or other municipal laws, and . . . all judgments for such penalties." FBAR penalties should not be enforced because they appear prima facie to fall within that description: they serve to punish a US citizen or green-card holder for his or her failure to report to the US government. Furthermore, FBAR penalties are not compensatory and do not affect the disgorgement of profits. (See Ivey; United States Securities and Exchange Commission v. Cosby, 2000 BCSC 338; and United States of America ( SEC ) v. Shull, 1999 CanLII 6625 (BCSC).
Harden makes it clear that taxes cannot be collected pursuant to registration of a civil judgment in a reciprocal jurisdiction. Although FBAR penalties are not taxes, it is highly likely that they are penal and thus are not enforceable in Canada. However, some uncertainty exists, and it may be possible to collect FBAR penalties in Canada on the principle of comity, discussed in Morguard Investments Ltd. v. De Savoye ([1990] 3 SCR 1077): a foreign judgment for a debt may be enforced in Canada if the party brings a separate action in a Canadian court.
In summary, a Canadian citizen need have little concern about the collection of US tax, interest, and ancillary penalties. However, a US taxpayer who is a Canadian resident and not a Canadian citizen and who owes US tax, interest, and penalties may face collection thereof by the CRA pursuant to treaty article XXVI A. It is extremely unlikely that Canadian citizens or residents will have to face collection of FBAR penalties, except in the very unlikely event that those penalties may be characterized as registrable civil judgments.
Erin L. Frew and S. Natasha Reid
Thorsteinssons LLP, Vancouver