Published: March 18, 2020
Last Updated: November 19, 2021
CRA can reallocate amounts to a non-competition or other restrictive covenant
Draft technical amendments to the Income Tax Act, released on February 27, 2004, BUT NOT ENACTED AS OF OCTOBER 2009, provide CRA (the Canadian Income Tax department) with the ability to reallocate amounts to a non-competition or other restrictive covenant. Last fall, the Department of Finance released proposals whereby non-competition and other restrictive covenants could be fully taxable, thus reversing the former tax advantage, based on case law, that was available in certain circumstances.
Disclaimer:
"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."
About the Author
