Federal Government extends Wage Subsidy and Rent Subsidy programs until June 2021

On March 3, 2021, the Government of Canada (the “Government”) announced additional particulars as to how the Canada Emergency Wage Subsidy (the “CEWS”) and the Canada Emergency Rent Subsidy (the “CERS”),will apply for Periods 14 to 16 (i.e., March 14, 2021 to June 5, 2021).

This release highlights the particulars announced on March 3, 2021. Additional commentary from our firm on the CEWS can be found here, here, here, here, here, here, here, here, here, here, here and here, and commentary on the CERS can be found here, here and here.

Existing Rate Structures

Prior to the Government’s announcement, the existing rate structures for the CEWS (for both active and furloughed employees) and the CERS (including the lockdown support subsidy) were set to expire at the end of Period 13 (i.e., March 13, 2021). The Government announced that it will extend the current rate structures for these programs until the end of Period 16 (i.e., June 5, 2021).

Revenue-Decline Reference Periods

Subject to certain deeming rules, CEWS and CERS applicants must demonstrate a revenue decline for each qualifying period using the general approach (which compares the qualifying revenue between a current reference period and a prior reference month) or the alternative approach (which compares the qualifying revenue of a current reference period and the months of January and February 2020). As set out in the table below, for Periods 14 to 16, the Government announced it will allow applicants who have used the general approach to calculate the organization’s revenue decline with reference to the applicable 2019 calendar month. Applicants must continue to use the approach they have chosen to use in prior periods (i.e. the general or alternative approach).

 

Period 14 (i.e., March 14 to April 10, 2021)

Period 15 (i.e., April 11 to May 8, 2021)

Period 16 (i.e., May 9 to June 5, 2021)

General Approach

March 2021 over March 2019 or February 2021 over February 2020

April 2021 over April 2019 or March 2021 over March 2019

May 2021 over May 2019 or April 2021 over April 2019

Alternative Approach

March 2021 or February 2021 over average of January and February 2020

April 2021 or March 2021 over average of January and February 2020

May 2021 or April 2021 over average of January and February 2020

 

Flexible Baseline Remuneration Periods

The Government has proposed a similar legislative amendment to compute baseline remuneration for purposes of the CEWS. For Periods 14 to 16, it is proposed that an eligible employer may elect to calculate baseline remuneration using the period of March 1, 2019 to June 30, 2019 or July 1, 2019 to December 31, 2019. The Government indicated that the Canada Revenue Agency will administer this measure on the basis of the draft legislative proposals that were released concurrently with the Government’s announcement.  The draft legislative proposals can be found here.

For assistance, please contact any members of our National Tax, Labour & Employment or Real Property & Planning teams.

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