Consultation Draft of Amendments to
Ontario's Corporate Minimum Tax
The 2007 Ontario Budget announced changes affecting the treatment of corporate reorganizations in connection with the calculation of Ontario's corporate minimum tax (CMT). A consultation draft of the regulatory amendments, with appended explanatory material, is posted in English on the Ministry of Finance's website.
The proposed amendments to the CMT regulations set out in the consultation draft would:
- make technical changes to the CMT mark-to-market rules in Ontario Regulation 509/07;
- implement the 2007 Ontario Budget amendments relating to CMT and corporate reorganizations; and
- codify the rules set out in Tax Legislation Bulletin 96-1R, entitled “Treatment of Corporate Reorganizations under the Corporate Minimum Tax”, originally released in 1994.
The consultation draft contains measures that apply both on a continuing basis and for past periods. Measures that apply on a continuing basis will also be included in regulations under the Taxation Act, 2007, given that the Corporations Tax Act is largely replaced by the Taxation Act, 2007 for taxation years ending after 2008.
