Tax Measures Under Canada's COVID-19 Economic Response Plan

Updated to include the 75% Canada Emergency Wage Subsidy

Since March 18, 2020, the Government of Canada announced a series of tax and economic measures under Canada’s COVID-19 Economic Response Plan (the “Response Plan”) to support the Canadian economy during the COVID-19 global pandemic. The Response Plan is designed to help stabilize the Canadian economy, and includes measures to assist both individuals and businesses through direct transfers, tax deferrals, and measures to ensure businesses continue to have access to credit.

On March 25, 2020, the Government of Canada passed Bill C-13, An Act respecting certain measures in response to COVID-19 (“Bill C-13”) to implement the Response Plan measures.

The original Response Plan has since been supplemented by measures announced on March 20, 2020 (“Additional Measures to Support Continued Lending to Canadian Consumers and Businesses”), and on March 27, 2020 (“Additional Support for Canadian Businesses from the Economic Impact of COVID-19”).

On April 1, 2020 the Government of Canada announced it would be supplementing the 10% wage subsidy previously enacted under Bill C-13 through the introduction of a 75% Canada Emergency Wage Subsidy (“CEWS”).  The CEWS will be non-cumulative with the existing 10% wage subsidy.

When combined with supplemental measures announced by the Government of Canada, the Response Plan is expected to provide $763 billion in direct and indirect support (including credit and liquidity support) to workers, families and businesses.

This summary explains the above measures as well as sales tax measures for goods and services tax/harmonized sales tax (“GST/HST”) and provincial sales tax (“PST”) registrants who are directly impacted by COVID-19.

Federal Tax Measures for Canadian Businesses

10% wage subsidy

The Response Plan contains measures to help businesses retain their workers. Framework legislation enacted as part of Bill C-13 created a federal payroll deduction rebate for remuneration an eligible employer pays between March 18, 2020, and June 19, 2020. Eligible employers are individuals, non-profit organizations, registered charities, Canadian-controlled private corporations (“CCPCs”) having a business limit in the last taxation year greater than nil (i.e. eligible for the small business deduction), and partnerships whose members are comprised solely of the foregoing persons. In addition, an eligible employer must:

  • have an existing business number and payroll program account with the Canada Revenue Agency (the “CRA”) as of March 18, 2020; and
  • pay salary, wages, bonuses, or other remuneration to at least one individual employed in Canada during the applicable period.

Bill C-13 provides that both the maximum prescribed amount of the rebate and the prescribed rate at which the rebate is to be calculated will be set by regulation. The rebate is expected to be 10% of remuneration paid by eligible employers to eligible employees during the applicable period, up to up to $1,375 per employee and to a maximum of $25,000 total per employer. Assistance received under the wage subsidy reduces the amount of remuneration expenses eligible for other federal tax credits calculated on the same remuneration.

The Department of Finance has further indicated that associated CCPCs would not be required to share the maximum subsidy of $25,000 per employer. Additionally, since the subsidy operates by allowing an eligible employer to reduce their payroll remittances, the Department of Finance suggested that if the amount of the subsidy exceeded an eligible employer’s payroll remittances for the applicable period, the employer would be allowed to continue to reduce remittances beyond June 20, 2020, or request the unclaimed amount be paid out to the eligible employer or credited against the eligible employer’s 2021 payroll remittances.

75% wage subsidy (CEWS)

On April 1, 2020, the Government of Canada released the details of the supplemental 75% CEWS:

  • Eligible employers include individuals, taxable corporations, partnerships consisting of eligible employers, non‑profit organizations and registered charities. An eligible employer must have experienced a 30% decrease in revenues during the “eligible period”. There is no overall limit on the CEWS amount an eligible employer can claim.
  • The CEWS has 3 eligible periods. In order for an eligible employer to claim the CEWS for a particular period, the eligible employer must meet the revenue decrease criteria for that period. Employers must reapply each month.
    • Period 1 - March 15, 2020, to April 11, 2020: to claim CEWS for the period from March 15, 2020, to April 11, 2020, compare to March 2020 revenues to March 2019 revenues;
    • Period 2 April 12, 2020, to May 9, 2020: to claim CEWS for the period from April 12, 2020, to May 9, 2020, compare to April 2020 revenues to April 2019 revenues;
    • Period 3 - May 10, 2020, to June 6, 2020: to claim CEWS for the period from May 10, 2020, to June 6, 2020, compare to May 2020 revenues to May 2019 revenues;
  • The decrease in revenue is calculated as follows:
    • For the majority of employers, using the employer’s normal accounting method to determine its revenue from business carried on in Canada earned from arm’s-length sources for the same month in the previous year, but excluding revenues from extraordinary items and amounts on account of capital.
    • For eligible employers established after February 2019, decrease in revenues will be calculated by comparing monthly revenues to a “reasonable benchmark”.
  • Employers will be required to attest to meeting the decline in revenue requirement.
  • In respect of non-profit organizations and charities, the Government of Canada has committed to working with the sector to ensure the definition of revenue is appropriately adjusted to the circumstances of non-profit organizations and charities.
  • The CEWS amount for eligible remuneration paid between March 15, 2020, and June 6, 2020 is the greater of:
    • 75% of remuneration paid, up to a maximum of $847 per week; and
    • The amount of remuneration paid, up to a maximum benefit of $847 per week or 75% of the employee’s “pre-crisis weekly remuneration” (to be defined in the coming days), whichever is less.
  • Eligible remuneration includes salary, wages, and other remuneration for which employers would generally be required to withhold or deduct to remit to the Receiver General on account of the employee’s income tax obligation. Eligible remuneration does not include severance pay, stock option benefits or personal use of a corporate vehicle.
  • CEWS for employees that do not deal at arm’s length with the employer will be limited to the eligible remuneration paid in any pay period between March 15, 2020, and June 6, 2020, up to a maximum benefit of $847 per week or 75% of the employee’s pre-crisis weekly remuneration.
  • Employers must make their “best efforts” to pay any remaining balance on employees’ salaries to bring them to pre-crisis levels. It is unclear what, if any, criteria will be used to determine if an employer is making “best efforts”.
  • Any amount received under 10% wage subsidy introduced in Bill C-13, as described above, will reduce the amount of the CEWS by that amount.
  • Employers cannot claim CEWS for an employee in a week that falls within a four-week period during which the employee is eligible for the Canada Emergency Response Benefit (described below under the heading “Temporary Income Support for Individuals”). Employer who are not eligible for the CEWS can still furlough employees who will receive up to $2,000 per month.
  • Any CEWS received by an employer is considered government assistance and must be included in the employer’s taxable income. Assistance received under CEWs reduces the amount of remuneration expenses eligible for other federal tax credits calculated on the same remuneration.
  • Applications will open online through the CRA in the coming weeks. Eligible employers can apply for the CEWS through the CRA’s My Business Account portal or a web-based application. Employers must keep records demonstrating their reduced revenues and remuneration paid to employees.
  • Employers who receive CEWS, but are not in fact eligible, must repay the CEWS and pay their employees accordingly. Penalties may apply to fraudulent claims and anti‑abuse rules will be proposed. New offences may be created for individuals, employers or business administrators who provide false or misleading information to obtain access to this benefit or who misuse any funds obtained under the program. Penalties may include fines or imprisonment.

Flexibility for Businesses in Respect of Paying and Filing Taxes

The Response Plan contains measures that will allow businesses to defer until September 1, 2020, the payment of any income tax that becomes owing between March 18, 2020, and August 31, 2020. Interest and penalties will not be applicable to these unpaid tax balances during this period. This measure will apply to both monthly instalments and year-end tax balances due under Part I of the Income Tax Act (Canada) (the “ITA”).

Generally, corporations (other than certain CCPCs) must pay income taxes owing under Parts I, VI, VI.1, and XIII.1 of the ITA on a monthly basis by the last day of each month. A corporation must also pay the remainder of any Part I taxes within 2 months (or in the case of certain CCPCs, 3 months) after its fiscal year-end. Under this measure, both of these payment deadlines are deferred until September 1, 2020, but only in respect of taxes levied under Part I of the ITA.

The deadlines to file certain categories of tax and information returns have been extended:

  • trusts having a taxation year ending on December 31, 2019, may defer filing T3 returns until May 1, 2020;
  • partnerships and their members may defer filing T5013 returns until May 1, 2020; and
  • the deadline to file NR4 information returns has been extended to May 1, 2020.

Additionally, unless otherwise noted by the CRA, administrative income tax actions required of taxpayers by the CRA due after March 18, 2020 can be deferred until June 1, 2020. Such actions include the filing of:

  • returns;
  • elections;
  • designations; and
  • information requests.

Curtailment of Audit and Reassessment Activity

For the vast majority of businesses, the CRA will temporarily suspend audit interactions with taxpayers and their representatives. The CRA will also refrain from initiating any post-assessment GST/HST or income tax audits with small or medium businesses for the next four weeks. More specifically, the CRA has issued the following relief measures:

  • Collections: No collection activities will be initiated on new debts until further notice, and the CRA undertakes to make flexible payment arrangements available. No collection action will be taken with respect to objections related to tax matters filed by individuals and businesses which are in abeyance (see Objections below). If a taxpayer is prevented from making a payment when due or filing a return on time, or from otherwise complying with a tax obligation because of circumstances beyond their control, then the taxpayer can submit a request to have interest and/or penalties waived or cancelled by using Form RC4288, Request for Taxpayer Relief. Payment arrangements are also available on a case-by-case basis if a taxpayer is unable to pay its taxes, child and family benefit overpayments, Canada Student Loans, or other government program overpayments in full. For pre-existing collections situations, these will be addressed on a case-by-case basis by collections staff to prevent financial hardship.
  • Audits: While the CRA has indicated that it will refrain from initiating any post-assessment GST/HST or income tax audits with small or medium businesses for the next four weeks, it has also specified that interaction with taxpayers will be limited to the cases where the legal deadline to reassess a tax return is approaching, and in cases of high risk GST/HST refund claims that require some contact before they can be paid out. The CRA has also expressed that for the vast majority of taxpayers, it would temporarily suspend audit interaction. Specifically, no new audits will be launched, no requests for information related to existing audits will be effectuated, no audits should be finalized, and no reassessments should be issued.
  • Objections: The CRA has indicated that any objections related to Canadians' entitlement to benefits and credits have been identified as a critical service which will continue to be delivered during COVID-19 times of hardship and therefore, there should be no delays associated with the processing of these objections. For any other objections filed by individuals and businesses related to other tax matters, the CRA is currently holding these accounts in abeyance. The deadline to make any objection requests due March 18, 2020, or later will be extended until June 30, 2020.
  • Appeals: Further to its Notice to the Public and the Profession on March 13, 2020, the Tax Court of Canada (“TCC”) announced on March 23, 2020, that all TCC sittings and conference calls scheduled between March 30, 2020, and May 1, 2020, inclusively, are cancelled. The Chief Justice will reassess on April 14, 2020. The Registry will contact affected parties directly. For all other business, the Registry is closed until further notice. In addition, the period from March 16, 2020, to May 1, 2020, is excluded from the computation of time prescribed by the rules of the TCC. Further, parties who file electronically are exempt from any requirement to file paper copies. However, documents will not be processed until the Court’s operations resume. If there is no statutory deadline, parties are asked to wait to file until the Court resumes operations.
  • Appeals to the CPP/EI Appeals Division: Appeals in respect of decisions made by the CRA on pensionability issues under the Canada Pension Plan (“CPP”), and insurability issues under the Employment Insurance Act (“EI Act”), will only be progressed where such appeals related to cases where EI benefits are pending. These cases will be considered on a priority basis. Other appeals will be continued when normal service resumes but neither the CRA nor the Minister of National Revenue have indicated when this is expected to occur. If additional time to respond to a request is required, the Minister of National Revenue will exercise discretion on a case-by-case basis.
  • Requirement to pay (“RTP”): Banks and employers do not need to comply or remit on existing RTPs.

Once the crisis has subsided, there will be a significant backlog for the CRA to deal with, and considerable delays for the foreseeable future.

Federal Tax Measures for Canadians

Temporary Income Support for Individuals

The Response Plan contains a new Canada Emergency Response Benefit (“CERB”) to support workers who have lost income due to the COVID-19 pandemic. The CERB replaces the previously announced Emergency Care Benefit and Emergency Support Benefit.

The CERB provides $2,000 per month for up to four months, which will be accessible online through CRA’s My Account or over the phone by automated service starting April 6, 2020. Canadians will begin to receive CERB payments by direct deposit within 3 to 5 days of application or within 10 days by mail, and it is paid every four weeks. It is available from March 15, 2020 until October 3, 2020. The CERB is available to the following workers:

  • workers who had to stop working due to COVID-19 and do not have access to paid leave or other income support.
  • workers who are sick, quarantined, or taking care of someone who is sick with COVID-19.
  • working parents who have to stay home without pay to care for sick children or need additional care because of school and daycare closures.
  • workers who still have their employment but are not being paid because employer asked them not to work due to insufficient work.
  • wage earners and self-employed individuals, including contract workers, who would not otherwise be eligible for Employment Insurance.
  • workers receiving the CEWS cannot also apply for the CERB.

Workers who qualify for Employment Insurance (“EI”) and are already receiving EI benefits will continue to receive them and should not apply for the CERB. But those whose EI benefits end before October 3, 2020, can apply for the CERB once their benefits cease if they are still unable to receive income due to COVID-19. Those who have already applied for EI, but their claim has not been processed, do not need to reapply. Workers who are eligible for normal course EI benefits can still access those benefits if they are still unemployed after the four-month period covered by the CERB.

 

Longer-Term Income Support for Workers

The maximum duration of the Work-Sharing program, which provides EI benefits to workers who agree to reduce their normal working hours as a result of developments beyond the control of their employers, is extended from 38 weeks to 76 weeks. In addition, eligibility requirements have been eased and the application process has been streamlined.

Income Support for Individuals

The Response Plan contains measures to boost assistance to low- and modest-income families through $7.5 billion of additional payments which will be made under existing benefit programs as follows:

  • A one-time special payment of a GST/HST credit to be paid by early-May 2020, which will double the maximum GST/HST credit for qualifying households for the 2019-2020 benefit year.
  • An increase to the maximum annual Canada Child Benefit (“CCB”) of $300 per child for the 2019-2020 benefit year, which is expected to be paid as part of the May 20, 2020, CCB payment date.

In recognition of the volatility in stock market conditions, the Response Plan also includes a measure to reduce required minimum withdrawals from Registered Retirement Income Funds (“RRIFs”) by 25% for 2020, to provide flexibility to annuitants who might otherwise be forced to liquidate investments to meet minimum RRIF withdrawal requirements. The Response Plan also notes that similar rules will apply to individuals who are receiving variable benefit payments under defined contribution registered pension plans.

While the Response Plan contemplates expanding the tools that the Canada Mortgage and Housing Corporation (the “CMHC”) and other mortgage insurers offer to lenders to increase flexibility for homeowners to defer mortgage payments on CMHC-insured mortgage loans, there is no suggestion that the Government of Canada intends to introduce measures to defer repayments of amounts withdrawn from registered retirement savings plans under the homebuyers’ plan.

Flexibility for Taxpayers

The CRA will defer the filing due date for 2019 tax returns as follows:

  • for individuals (other than trusts) until June 1, 2020 (from April 30, 2020); and
  • for those trusts having a taxation year ending on December 31, 2019, until May 1, 2020 (from March 31, 2020).

Any income tax that becomes owing by the taxpayers between March 18, 2020, and August 31, 2020, under Part I of the ITA will be deferred until September 1, 2020.

Taxpayers who are unable to file a return or make a payment by the deadlines as a result of COVID-19 can request the cancellation of penalty and interest charged to their account. Penalties and interest will not be charged if the new deadlines that the government has announced to tax-filing and payments are met. For more information about taxpayer relief and how to make a request to the CRA to have interest and/or penalties cancelled, please go to Canada.ca/taxpayer-relief

To reduce the administrative burdens and the necessity for taxpayers to meet with tax preparers in person, the CRA will recognize electronic signatures as having met the signature requirements of the ITA on a temporary basis. This will allow certain authorization forms (T183 Information Return for Electronic Filing of an Individual's Income Tax and Benefit Return, or T183CORP Information Return for Corporations Filing Electronically), which normally require signed originals, to be signed electronically.

Federal Tax Measures for Charities

Flexibility for Registered Charities

The Charities Directorate implemented the following measures:

  • The filing deadline for all charities with a Form T3010, Registered Charity Information Return, due between March 18, 2020 and December 31, 2020 is postponed to December 31, 2020.

Deferral of the GST/HST Remittance and Customs Duty Payments

GST/HST Remittance Deferral

To support Canadian businesses (including self-employed individuals registered for GST/HST purposes), the Government of Canada announced on March 27, 2020, that it would defer to June 30, the due dates of the GST/HST collected by the following persons and for the following periods:

  • Monthly filers for GST/HST collected for the February, March and April 2020 reporting periods;
  • Quarterly filers for the GST/HST collected for the January 1, 2020 through March 31, 2020 reporting period; and
  • Annual filers, for GST/HST returns or instalments are due in March, April or May 2020, for GST/HST collected and owing for their previous fiscal year and for instalments of GST/HST in respect of the filer’s current fiscal year.

Deferral of Customs Duty and GST for Importers

In a commercial goods importation context, payments owing for customs duties and GST at a rate of 5% on imports are generally due before the first day of the month following the month in which the statements of accounts are issued to the importers of commercial goods. The Government of Canada has also announced that payment deadlines for statements of accounts for March, April, and May are deferred to June 30, 2020.

The government stated that both of these measures provide the equivalent of up to $30 billion in interest-free loans to Canadian businesses and they will help businesses continue paying their employees and their bills, and help ease cash-flow challenges across the country.

Alberta Tax Measures

On March 18, 2020, the Government of Alberta released the following tax measures:

Measures for businesses

  • Businesses with corporate income tax balances owing or installment payments coming due between March 18, 2020, and August 31, 2020 will be able to defer these payments until August 31, 2020. Penalties and interest that would otherwise be payable in respect of these payments will be waived. However, businesses must continue to file their Alberta corporate tax returns as required. The deferral does not apply in respect of tax balances or installment payments made prior to March 18, 2020.
  • Education property tax rates will be frozen at 2019 levels, reversing the planned 3.4% increase added in 2020 Alberta Budget. Moreover, collection of non-residential education property tax for businesses will be deferred for six months. Municipalities are expected to set the education property tax rates as they normally would, but to defer collection. Any deferred amounts will be repaid in future tax years.
  • The Government of Alberta will modify its corporate income tax audit and collection practices during the COVID-19 pandemic, but did not provide specific details on the proposed modifications.

Measures for individuals

  • Education property tax rates will be frozen at 2019 levels, reversing the planned 3.4% increase added in 2020 Alberta Budget.

British Columbia Tax Measures

On March 23, 2020, the Government of British Columbia announced the following tax measures as part of its “BC COVID-19 Action Plan”, which commits $5 billion in income supports, tax relief and direct funding for people, businesses and services.

Measures for business

Effective as of the March 23, 2020 announcement date, the filing and payment deadlines for the following provincial taxes will be deferred until September 30, 2020:

  • employer health tax;
  • PST;
  • municipal and regional district tax on short-term accommodation;
  • tobacco tax;
  • motor fuel tax; and
  • carbon tax.

The following tax measures announced in the February 18, 2020, British Columbia budget have been postponed until at least September 30, 2020, on which date the Government of British Columbia intends to review the postponement:

  • the scheduled April 1 increase to the provincial carbon tax;
  • the new PST registration requirements for foreign sellers of software and telecommunication services; and
  • the implementation of PST on sweetened carbonated drinks.

There will be a 50% reduction in school tax rates for commercial properties (Classes 4, 5 and 6) for the 2020 tax year.

Measures for individuals

A new B.C. Emergency Benefit for Workers will provide a one-time, tax-free $1,000 payment to residents of British Columbia. Residents of B.C. who receive federal Employment Insurance or the new Canada Emergency Response Benefit (replacing the federal Emergency Care Benefit and the federal Emergency Support Benefit) are eligible.

The Government of British Columbia also intends to make a one-time special payment to individuals who receive the B.C. Climate Action Tax Credit, which will be paid in July 2020:

  • an adult will receive up to $218.00 (increased from $174.00); and
  • a child will receive $64.00 (increased from $51.00).

Manitoba Tax Measures

On March 22, 2020, the Government of Manitoba announced the following tax measures:

Measures for businesses

  • April and May filing deadlines for small and medium-sized businesses with remittances of $10,000 or less are extended by two months, thus providing these businesses extra time to remit PST (retail sales tax) and payroll tax (Health and Post Secondary Education Tax Levy).
  • The Department of Finance and Taxation will consider flexible repayment options for businesses with remittances of more than $10,000.

Other measures

  • In person service at the Taxation Division Offices is not available. Services are continuing by telephone and online.

Newfoundland and Labrador Tax Measures

On March 22, 2020, the Government of Newfoundland and Labrador issued a Public Advisory that in person tax administration services are temporarily suspended.

  • Taxpayers may submit tax returns, applications and payments online, by email ([email protected] for returns and [email protected] for all other transactions), by post or by using the drop-off box.
  • Telephone lines are open to set up electronic funds transfer, wire payment, or e-file payment options (709-729-6297 or toll free 1-877-729-6376).

Northwest Territories Tax Measures

On March 20, 2020, the Government of the Northwest Territories (“GNWT”) announced the following tax measures:

Measures for businesses

  • GNWT has paused most collection efforts to provide small businesses and individuals with access to greater cash flow, including outside collection agency activity, GNWT set-offs on GNWT payments, GNWT set-offs on Canada Revenue Agency tax refunds.

Measures for individuals

  • GNWT has paused most collection efforts to provide small businesses and individuals with access to greater cash flow, including outside collection agency activity, GNWT set-offs on GNWT payments, GNWT set-offs on Canada Revenue Agency tax refunds.
  • Funding for the normal-course Income Assistance Program has been increased.

Nova Scotia Tax Measures

Between March 20 and 27, 2020, Premier Stephen McNeil announced the following tax measures:

Measures for businesses

  • Payments on all government loans and small business fees (including business renewal fees and workers compensation premiums) are deferred until June 30, 2020.
  • Retail and commercial landlords who defer lease payments for the next 3 months for businesses that had to close as a direct result of the public health order will be able to claim losses up to $5,000 per month if the renting business does not continue operating.

Ontario Tax Measures

On March 25, 2020, the Government of Ontario released Responding to COVID-19 (March 2020 Economic and Fiscal Update), which will make $10 billion available to support individuals and businesses through tax and other deferrals:

Measures for business

  • Businesses will benefit from five months of interest and penalty relief in relation to filing and making payments for the majority of provincially administered taxes.
  • Upcoming June 30 quarterly municipal remittance of education property tax to school boards is deferred by 90 days.
  • Employers may defer payments to the Workplace Safety and Insurance Board (“WSIB”) for up to six months.
  • The Employer Health Tax (“EHT”) exemption will be increased to cut taxes by $355 million for approximately 57,000 employers.

Measures for individuals

  • Upcoming June 30 quarterly municipal remittance of education property tax to school boards is deferred by 90 days.

Prince Edward Island Tax Measures

The Government of Prince Edward Island (“PEI”) announced the following measures:

Measures for businesses

  • Registered private sector businesses or non-profit organizations where employees’ hours have been reduced at least 8 hours per week during the period from March 16, 2020, to March 29, 2020, are eligible for the Emergency Relief - Worker Assistance Program. The program provides up to $250 per week for each employee. Online application can be submitted until April 15, 2020. Workers who have been laid off are not eligible.

Measures for individuals

  • An Emergency Income Relief Fund provides up to $500 per week for the period from March 16, 2020, to March 29, 2020, to self-employed individuals affected by COVID-19. Eligible criteria require that the self-employed individual:
    • declared business income on their most recent tax return;
    • earn business income as the primary source of income;
    • can demonstrate direct financial losses from COVID -19 isolation measures at the time of application; and
    • is not eligible for EI or other income support.

Quebec Tax Measures

On March 17, 18 and 19, 2020, the Government of Quebec announced its own relief measures in response to the COVID-19 pandemic: Bulletins 2020-3, 2020-4 and 2020-5, a March 18th Press Release (“March 18 PR”), a March 19th Press Release (“March 19 PR”), as well as a March 27th Press Release (“March 27 PR”).

Measures for corporations 

  • The payment of tax instalments and the balance of tax otherwise due between March 18, 2020, and September 1, 2020, will be postponed to September 1, 2020.

Measures for trusts 

  • The deadline for trusts, other than a testamentary trust subject to progressive rate taxation, but including specified investment flow-through (“SIFT”) trusts, to file income tax returns is extended from March 30, 2020, to May 1, 2020. 
  • The deadline for filing the tax return of a testamentary trust subject to progressive rate taxation whose taxation year ends in 2019, and whose filing due date would otherwise be after March 16, 2020, is postponed to May 1, 2020.
  • The deadline for a trust (other than a SIFT) to pay any balance of tax due no later than March 30, 2020, for the 2019 taxation year will be postponed to September 1, 2020.
  • The payment of tax instalments and the balance of tax otherwise due by SIFTs between March 17, 2020, and September 1, 2020, will be postponed to September 1, 2020.

Measures for individuals 

  • The deadline to file an income tax return is postponed to June 1, 2020, for individuals whose tax return filing-due date, for the 2019 taxation year, would otherwise be April 30, 2020.
  • The deadline for filing an income tax return for the 2019 taxation year of an individual who died in that year, but before December 1, 2019, is postponed to June 1, 2020.
  • The deadline for filing an income tax return for individuals who carried on a business in 2019, or whose spouse carried on business, remains June 15, 2020.
  • The deadline to pay (i) any balance of tax due, and/or (ii) Québec Pension Plan, Québec Parental Insurance Plan, Health Service Fund, and Québec drug insurance plan contributions for the 2019 taxation year is postponed to September 1, 2020.
  • The deadline to make instalment payments for the 2020 taxation year will be postponed to September 1, 2020.
  • The minimum withdrawal by annuitants from their RRIFs is reduced by 25% for 2020.
  • The Quebec Temporary Aid for Workers Program (“PATT COVID-19”) grants a lump sum of $573 per week to eligible workers for a period of 14 days of isolation. If justified, the coverage period could be extended to a maximum of 28 days. Since March 19, 2020, workers can apply to the PATT COVID-19 if they were (or are) in isolation because they had contracted the virus or are showing symptoms, had been in contact with an infected person or had returned from abroad. Workers are not eligible if:
    • they are being compensated by their employer;
    • they have private insurance; or
    • they are covered by another government program, including the federal employment insurance.
  • Requests or renewals of advanced payments from the tax credit for home-support services for seniors that would otherwise be filed between March 17, 2020, and June 1, 2020, are granted an extra four months from the renewal date to make the request. Current payments are maintained in the meantime.
  • Deadlines to submit renewal requests to the Housing Allowance Program (“PAL”) are extended by 2 months to a deadline no later than December 1, 2020.

Despite the extension of the filing deadline, individuals should file their income tax return as soon as possible if they expect to receive an income tax refund. 

Measures for partnerships 

  • Partnerships that had to file a form TP-600-V, Partnership Information Return, for 2019 by March 31, 2020, now have until May 1, 2020, to file the return if all members of the partnership are individuals.
  • Partnerships in which all members are corporations must file the Information Return within five months of the end of the fiscal year. Where the deadline would otherwise fall between March 16, 2020, and May 1, 2020, the date is postponed to May 1, 2020.
  • In any other situation, the 2019 return must be filed by May 1, 2020, or the last day of the fifth month following the end of the fiscal year, whichever comes first. But if the last day of the fifth month is after March 16, 2020, the deadline for filing is May 1, 2020.
  • The payment of tax instalments and the balance of tax otherwise due by specified investment flow-through partnerships between March 17, 2020, and September 1, 2020, will be postponed to September 1, 2020.

Measures for charities

  • A registered charity whose Information Return for Registered Charities and Other Donees (form TP-985.22) is due between March 17, 2020, and December 30, 2020, may file by December 31, 2020.

Measures for QST registrants and other measures

On March 27, 2020, the Government of Quebec announced that it would allow registrants to defer until June 30, 2020, the filing of QST returns and corresponding QST payments, where appropriate, for all QST returns that must be filed between March 27, 2020, and June 1st, 2020, without interest or penalties. This measure is in line with the GST/HST measure announced by the Government of Canada.

In addition, the Government of Quebec will accelerate the processing of requests for tax credits intended for businesses and tax refunds. Through the new measures, the government is adding $7.3 billion to companies’ liquid assets in the coming months for the postponement of the QST payment and more than $600 million in accelerated payments of tax credits.

Other measures 

To limit in-person contact, Revenu Québec will allow tax preparers to use an electronic signature on certain forms. The forms in question are form TP-1000.TE-V (Online Filing of the Personal Income Tax Return by an Accredited Person) and form CO-1000.TE (Online Filing of the Corporation Income Tax Return by an Accredited Person). The information sessions usually broadcast in person to individuals and businesses, and the support program for small and medium-sized businesses, are now offered by telephone.

Revenu Québec has also has issued the following relief measures regarding audit and collection activities, objection, and appeals.

  • Audits and collections: Audits and collection activities are being limited. Concerning collection measures, Revenu Québec has indicated that it will be amenable, on a case-by-case basis, to extending payment agreements.
  • Objection: Deadlines for objections to reassessments are extended, such that the expiration of any 90-day period that falls between March 13, 2020, and June 29, 2020, is postponed to June 30, 2020.
  • Appeals: deadlines are suspended from March 15, 2020, until the end of the COVID state of emergency. This applies to the following procedural matters:
    • Appeals of assessments brought to the Court of Quebec;
    • Summary appeals to the Small Claims Division of the Court of Quebec;
    • Requests for review of a decision of the Minister of Revenue refusing to extend the time for filing an objection;
    • Requests to extend the time to file an appeal or a summary appeal.

Revenue Québec is postponing administrative tax filing deadlines (other than returns with specific postponement dates listed above) that fall between March 17, 2020, and May 31, 2020, to June 1, 2020. This postponement applies to the following non-exhaustive list:

  • corporate income statement;
  • Quebec tax laws or regulations election such as a rollover (except QST choices that are harmonized with GST);
  • tax credit application (12 month deadline);
  • request for reimbursement of fuel taxes;
  • response to requests for information from Revenu Québec;
  • mandatory or preventive aggressive tax planning (“ATP”) disclosure;
  • Quebec education savings incentive (“QESI”) request (90-day deadline).

In addition, the deadline to remit any unclaimed property to the Minister of Revenue, which corresponds to the end of the first quarter following the end of the fiscal year in which the property has become unreported, is postponed to August 31, 2020. No late payment interest or penalties in respect of property which has become unclaimed during a fiscal year ending between December 17, 2019, and May 30, 2020, will accrue as long as the property is remitted to Revenu Québec before September 1, 2020. The 10-year limitation period for remitting amounts less than $ 500 to the Minister of Finance is suspended until the expiration of the COVID state of emergency.

Saskatchewan Tax Measures

On March 20, 2020, Premier Scott Moe announced the following tax measures:

Measures for businesses

  • Penalties and interest charges are deferred for 3 months for businesses who are unable to remit their PST due to cash flow issues.
  • As described in Information Bulletin IN 2020-03:
    • Businesses that are unable to file their provincial sales tax returns by the due date may submit a request for relief from any interest or penalties that would otherwise apply to such late filings.
    • Penalty and interest waiver requests can be submitted electronically through the Saskatchewan eTax Service (“SETS”) located at saskatchewan.ca, by email ([email protected]) or at the following address: Ministry of Finance (Revenue Division), PO Box 200, Regina, SK, S4P 2Z6.
  • Audit program and compliance activities have been suspended so businesses can prioritize the health and safety of customers and staff, conserve resources and reduce audit travel.
  • A single window information webpage will be established for businesses to access information and receive timely updates on provincial support initiatives. A Business Response Team, led by the Ministry of Trade and Export Development, will work with businesses to identify program supports relevant to particular businesses.

Measures for individuals

  • The Self-Isolation Support Program will provide $450 per week, for a maximum of two weeks or $900 to Saskatchewan residents forced to self-isolate, who are not covered by the federal plan or other supports. Eligibility criteria are:
    • they have contracted COVID-19 or are showing symptoms;
    • they have been in contact with an infected individual;
    • they have recently returned from international travel and must self-isolate;

AND

  • they are not eligible for compensation from their employer such as sick leave or vacation;
  • they do not have private insurance covering such matters;
  • they are not covered by federal programs.

Yukon Tax Measures

The Government of Yukon announced the following measures:

Measures for businesses

  • Employers can apply for the Paid Sick Leave Rebate to pay up to $378.13 per day per employee for ten business days for employees who take sick days or self-isolate. The funding is only accessible once all existing regular paid sick leave for the employee is used. Employers can only access the program once per employee. To be eligible, the employer must:
    • have an office with a physical address in Yukon;
    • be subject to the Yukon Income Tax Act;
    • be registered as per the Business Corporations Act or the Partnership and Business Name Act, where applicable;
    • have a valid municipal business licence where applicable.

Measures for individuals

  • The Paid Sick Leave Rebate provides up to $378.13 per day for ten business days to employees and self-employed workers who contract COVID-19 or are required to self-isolate. The program is available from March 11, 2020, to September 11, 2020. Applicants can only access the program once.

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