Federal Budget 2026 – Key Income Tax Measures
November 6, 2026
The federal government announced its annual budget on November 5, 2026. PPI’s Professional Services team has prepared a summary of budget proposals. This article does not contain a complete list of proposals but outlines the ones relating to the financial services industry
Executive summary
The Budget contains no material changes to corporate-owned life insurance, the capital dividend account, leveraged insurance arrangements, the general capital gains inclusion rate, or the lifetime capital gains exemption.
Key proposals include:
the new $15-million Canada Growth Incentive,
relief from Part VI.1 tax for Canadian-controlled private corporations (CCPCs),
restrictions on certain trust rollouts involving non-residents,
proposed corporate loss transfers,
changes affecting individual pension plans,
selected cross-border measures,
an expanded intergenerational rollover for farm and fishing property,
revised corporate holdings rules for private foundations,
a common May 15 tax-filing deadline for individuals, and
simplified filing requirements for certain corporate tax elections.
The Canada Growth Incentive: new $15 million capital gains exemption
The Budget proposes a new capital gains exemption of up to $15 million per qualifying individual, per qualifying business, for qualifying shares issued on or after November 5, 2026 and before 2037.
The shares must have been newly issued directly to the individual, or to a partnership in which the individual is a member, for cash or qualifying employment services.
The issuing corporation must be a CCPC when the shares are issued, and the corporation and related corporations must have no more than $100 million of aggregate asset carrying value immediately before and after issuance.
The shares must be held for at least 36 months. At issuance and disposition, all or substantially all of the corporation’s value must relate to assets used in a qualifying business; during ownership, the threshold is at least 50 per cent.
The exempt gain would have a 30-per-cent inclusion rate for alternative minimum tax purposes.
The excluded business rules are extensive. Professional practices, consulting, insurance and financial services, real estate, accommodation and food services, arts and recreation, licensed businesses, franchises, and businesses principally dependent on employee reputation or skill do not qualify.
This is not a general exemption for the sale of an owner-managed business. It appears directed primarily at founders and investors in scalable growth companies.
The previously proposed Canadian Entrepreneurs’ Incentive (CEI) appears no longer to be part of the government’s legislative agenda. The CEI would have effectively reduced the inclusion rate on up to $2 million of qualifying gains. It was never enacted and is not included in the Budget’s list of previously announced measures the government intends to pursue. The Canada Growth Incentive is a completely separate policy successor.
Part VI.1 relief for CCPC taxable preferred shares
The Budget proposes to exclude dividends paid by a CCPC from the Part VI.1 taxable preferred-share regime, effective for dividends paid on or after Budget Day. It also proposes increasing the general annual dividend allowance from $500,000 to $1.5 million and the prior-year dividend threshold that reduces the allowance from $1 million to $3 million, for taxation years ending after 2026.
This is potentially significant for estate freezes, preferred-share reorganizations, charitable preferred share gifts, shareholder agreements and other fixed-value preferred share planning. If the payer remains a CCPC, the exemption may eliminate an issue that previously required detailed review under sections 191 and 191.1 of the Income Tax Act.
Intergenerational farm and fishing property rollover
The tax-deferred rollover for qualifying farm and fishing property would be expanded to transfers to a niece, nephew, grandniece or grandnephew of the taxpayer or the taxpayer’s spouse or common-law partner. The change would apply to transfers on or after January 1, 2027.
Private foundations
The excess corporate holdings regime for private foundations would be eliminated. Instead, private foundations would be prohibited from acquiring control of a corporation, consistent with the rules applicable to public foundations. The change would apply to taxation years beginning on or after January 1, 2027.
Trust rollouts involving non-resident ownership
The Budget proposes to deny a tax-deferred trust rollout where property is distributed to a corporation or partnership with a direct or indirect non-resident shareholder or partner. The proposal applies to distributions on or after Budget Day.
Before relying on subsection 107(2) of the Income Tax Act, practitioners may need to examine the full ownership chain of a corporate or partnership beneficiary. This may be particularly relevant where a family trust or related corporate structure includes U.S.-resident family members. The breadth of “direct or indirect” ownership should be revisited when the statutory language is available.
It is important to note that some types of trust rollout planning involving non-residents are currently subject to reporting under the current “notifiable transaction” rules using CRA Form RC312, Reportable Transaction and Notifiable Transaction Information Return. However, if enacted, the proposed measure now would move beyond simply disclosure to potential scrutiny under the general anti-avoidance rule (GAAR).
Proposed corporate-loss transfer system
The government is consulting on transfers of current-year non-capital losses between a parent and wholly-owned subsidiary, or between wholly-owned sister corporations. The preliminary framework would require taxable Canadian corporations, a joint annual election and permanent establishments in only one province or territory and in the same province or territory. Transferred losses could not be carried forward or back.
Pension and retirement measures
The Budget proposes tighter rules for Individual Pension Plans, particularly plans involving related people, unusual investments or significantly more assets than are needed to fund the promised pensions. A seriously non-compliant registered pension plan could face a 10% tax and may be treated as a Retirement Compensation Arrangement, potentially triggering the RCA’s 50% refundable tax. The government will also consult on an “RRSP for life,” which could allow individuals to keep their RRSP after age 71 rather than converting it to a RRIF, although minimum annual withdrawals would still be required.
The IPP proposals warrant attention in insured retirement, corporate-owner and business-succession files. The RRSP proposal could simplify spousal succession and post-mortem administration, but it is presently only a consultation.
Cross-border and compliance measures
Proposed measures include:
Increase the basic Form T1135 threshold from $100,000 to $200,000 and the upper limit for simplified reporting from below $250,000 to below $500,000, for taxation years or fiscal periods ending after 2026.
Reduce certain section 116 withholding rates from 25 per cent to 15 per cent, and from 50 per cent to 30 per cent for specified taxable Canadian property.
Facilitate certain fully tax-deferred section 85 transfers of taxable Canadian property, generally for dispositions on or after January 1, 2027.
Permit the CRA, subject to safeguards, to report tax debts exceeding $50,000 to credit bureaus.
Corporate tax elections
Corporations would no longer need to provide a certified directors’ resolution or authorization when filing certain tax elections or agreements with the CRA. A certified copy of the directors’ resolution is currently required when filing a capital dividend election. Removing this requirement should reduce the time and cost associated with preparing and filing the election.
The change would apply to elections and agreements made on or after the enacting legislation receives Royal Assent.
Individual tax-return filing and payment deadlines
The T1 filing and balance-due date would become May 15 for all individuals, including self-employed individuals and their spouses or common-law partners. The change would apply beginning with the 2027 taxation year.
What was not in the Budget
No change to the general capital gains inclusion rate.
No change to the small business deduction or the $500,000 business limit.
No increase to, or restructuring of, the regular lifetime capital gains exemption.
No change to corporate-owned life insurance, policy adjusted cost basis, subsection 148(1), subsection 148(7), or capital dividend account credits arising on death.
No targeted measure addressing immediate financing arrangements, leveraged insurance, interest deductibility, or corporate borrowing secured by life insurance.
No change to post-mortem pipeline planning, subsection 84(2), graduated rate estates, or family trust 21-year rules.
This briefing is a preliminary professional summary, not legal or tax advice. The proposals may undergo revisions before becoming law, and should be confirmed against enacted legislation, including explanatory notes.
continue reading