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2024 Year-end Tax Planning Tips - Corporations

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2024 Tax Updates


CCPC (Canadian Controlled Private Corporation) tax rates:


  • CCPC small business tax rate: remained at 12.2% in 2024 (combined Federal and Ontario, for taxable active business income up to $500,000, payable 3 months after the fiscal year-end, otherwise 2 months after the fiscal year end).

  • CCPC passive income tax rate: remained at 50.17% in 2024. Refundable portion remained at 30.67%. Note: Any CCPC passive income above $50,000 will grind down its small business limit at a 5 times rate (limited to federal tax only, not for Ontario SBD). Contact us for strategies to minimize.

  • Refundable Part IV tax rate and dividend refund rate: on taxable dividends paid by a corporation remained at 38.33% in 2024. Note: The dividend refund is now split into a complex eligible and non-eligible RDTOH regime. Contact us for more details.

 


Other updates:


  • Capital gains inclusion rate: Increased from ½ to ⅔, for capital gains realized after June 24, 2024. Corporations do not have the $250,000 threshold for the ½ inclusion rate as is available to individuals and graduated rate trusts.

  • Canada Carbon Rebate for CCPC: If your business is a CCPC with less than 500 employees in Ontario, ensure that your 2023 corporate tax return is filed by Dec 31, 2024 to receive this new rebate retroactively from 2020 to 2024.

  • Canada Emergency Business Account (CEBA): any CEBA loan balance would have been converted to a three-year term loan with 5% annual interest rate and must be fully paid by December 31, 2026.

  • Beneficial ownership registries: Already a requirement for federally incorporated companies in 2024. Provincial requirements for privately-held companies to maintain ownership registries proposed in Ontario. Ontario corporations must file an annual return via the Ontario Corporate Registry.

 


Small Business Owners

 

Owner-manager remunerations:


  • Preferred salary/dividends mix: Determine the preferred mix of salary and dividends for you and your family members for 2024 with consideration for the TOSI rules. Discuss with us for optimal dividend for family members, if meeting the requirements for excluded business or excluded shares.

    • Consider paying a reasonable salary instead, especially for a personal taxable income below $55,000, with proper support to justify the pay.

    • Paying enough taxable dividend to receive all the RDTOH refund inside the company.

    • Salary will be more favored in 2024 owing to the new AMT regime.

  • Bonus accruals at year end must be paid within 179 days after the corporate year end, including appropriate source deductions and payroll taxes to be remitted on time.

  • Tax-effective dividends: Make tax-effective dividends such as non-taxable capital dividend before a capital loss is triggered.

  • Preserve cash in the corporation in times of uncertainty.



Year-end tips:


  • Purchase eligible zero-emission vehicles and take advantage of an immediate write-off (i.e. 100% CCA deduction) available for purchases after March 18, 2019, in the year the vehicles first become available for use (subject to a gradual phase-out after 2023 and before 2028: 2024 and 2025 is 75%).

  • Purchase capital asset for CCA class 44, 46 and 50: Class 50 includes computer equipment and related system software. Take advantage of an immediate write-off (i.e. 100% CCA) before 2027.

  • Claim a business reserve to defer tax on related profits by claiming a reserve on unpaid amount over a maximum of three years, if you sold goods or real property inventory in 2024 and proceeds are payable after the end of the year.

  • Claim a capital gains reserve: if you receive proceeds that include debt – over a maximum of four years (resulting in the capital gain being included in income over a maximum five years).

  • Shareholder loans to your corporation – Determine whether your corporation would benefit from deductible interest on shareholder loans made to the corporation, rather than additional salary or bonus payments that may be subject to payroll taxes.

  • Repay shareholder loans from your corporation on later than the end of the tax year after the one in which the amount was borrowed.

  • Use of private health services plan (PHSP) premiums instead of non-deductible medical expense, but careful where the sole shareholder is the sole employee.

  • Buy company owned life insurance policy to utilize corporate retained earnings and defer passive income.

  • Track motor vehicle use for business: maintain a logbook of mileage (including date, destinations, distance KMs, and purpose). Try to increase the business mileage to greater than 50% to reduce the standby charges of a company car.

  • Apply for SR&ED tax incentives: CCPC may have the ability to access the enhanced (and refundable) 35% SR&ED ITC. Ensure claims in respect of eligible SR&ED expenditures or ITCs are filed by the deadline (within 18 months after the year-end).

  • Taxable capital: If your CCPC’s taxable capital for federal tax purposes in 2024 exceeds $10 million, together with all associated companies, it will start losing access to the small business deduction and the enhanced 35% SR&ED ITC rate in 2024 (with access lost entirely once taxable capital exceeds $50 million). Monitor your taxable capital and discuss with us for ways to reduce taxable capital before your company’s year end.

  • Create a company stock options plan: To potentially obtain a 50% income deduction (note the new restrictions to $200,000 is for public companies only, not impacting CCPC). Note the stock option deduction decreases to 1/3 from June 24, 2024. Individuals can still benefit from a deduction of 1/2 of the taxable benefit up to a combined $250,000 for both employee stock options and capital gains.

  • Lifetime capital gains exemption (LCGE): Organize the business so that corporate shares become or remain eligible for the $1,250,000 (indexed) lifetime capital gains exemption (LCGE), which is available to all individuals. Discuss with a tax specialist for the complexities, including estate freeze and intergenerational transfers.

  • Canadian Entrepreneur’s Incentive (CEI): Organize the business so that the shares of your small business corporation become eligible for the CEI. Starting 2025, the CEI reduces the capital gain inclusion rate from 2/3 or ½ to 1/3 on up to $2 million of capital gains per individual during their lifetime.

 


Corporate matters:


  • Income from property: may be eligible for small business rate if CCPC has more than five full-time employees.

  • Mandatory e-filing of corporate income tax return – to avoid penalties – if corporate annual gross revenues exceed $1 million.

  • PSB Issue: Be mindful of personal services business (PSB), tax rate is at 44.5% in 2024. See our website: https://www.impactcpas.ca/post/tax-implications-for-employee-vs-self-employed and discuss with us.

  • QST/PST registration: If your business makes digital and certain other supplies to “specified Quebec consumers”, even if it is not resident in Quebec and has no physical establishment in the province, consider whether it is required to register under the simplified QST regime (threshold $30,000). Similar requirement exists in BC as well for its PST registration with a threshold at $10,000.




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©2024 IMPACT CPA LLP, an Ontario limited liability partnership. All rights reserved.

The content of this pamphlet is prepared by IMPACT CPA LLP for information only and are not intended to provide professional advice as individual situations will differ. We would be pleased to discuss your specific situation and tailor a tax plan to meet your requirements.

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