Kim G C Moody FCPA, FCA, TEP
Founder and Director
Moodys Private Client, Moodys Tax
More about this webinar
Bill C-31 — the Budget 2025 Implementation Act, No. 2 — received first reading on May 6, 2026. Several provisions require immediate attention from practitioners advising family business owners, immigrant clients, and corporations with investment income. This webinar covers the mechanics, the planning implications, and the specific advisory actions you need to take before year-end.
Agenda:
Bill C-31 overview and what’s new
What the bill covers, why it matters for your practice, and a triage of provisions by risk level.
s. 120.4(1)TOSI definition amendments
Changes to the excluded shares and split income definitions. Every family corporate structure needs re-examination under the new wording.
s. 128.1(8.1)Post-immigration loss rule
New restriction on using post-immigration losses to shelter pre-Canadian-residency gains. Material for any client who immigrated with foreign property.
s. 129(1.2)Dividend anti-avoidance — RDTOH
New rule denying RDTOH refunds where the dividend is part of an avoidance arrangement. Tiered holding structures take note.
s. 150(1.5)–(1.6)Automatic tax filing
Canada’s first deemed filing regime: who qualifies, how it works, and why the misrepresentation trap in s. 150(1.6) is a serious concern for the very population it targets.
Recent case law highlights + Q&A
Selected recent decisions relevant to the provisions covered, followed by open Q&A.