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Table 2
Corporate Income Tax Expenditures*


Estimates Projections1


2001 2002 2003 2004 2005 2006 2007 2008

($ millions)
Charities, Gifts and Contributions
Deductibility of charitable donations2 490 295 260 320 360 395 415 405
Deductibility of gifts of cultural property and ecologically sensitive land3 13 26 9 24 9 9 9 9
Deductibility of gifts to the Crown S S S S S S S S
Non-taxation of registered charities n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Non-taxation of other non-profit organizations (other than registered charities) 185 175 160 160 145 165 165 185
Political contribution tax credit4 S S S S S S
Culture
Canadian film or video production tax credit 160 155 150 165 175 185 195 205
Non-deductibility of advertising expenses in foreign media n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Federal-Provincial Financing Arrangements
Income tax exemption for provincial and municipal corporations n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Transfer of income tax room to provinces 1,145 1,065 1,210 1,455 1,590 1,730 1,810 1,855
Logging tax credit5 17 22 14 59 36 39 40 42
General Business and Investment
Accelerated write-off of capital assets and resource-related expenditures n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Deferral through capital gains rollovers n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Taxation of capital gains upon realization n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Partial inclusion of capital gains6 3,270 2,320 2,465 3,330 3,170 3,370 3,525 3,565
Expensing of advertising costs7 50 -80 30 45 35 35 40 40
Atlantic investment tax credit8
   Earned and claimed in current year 110 91 67 120 130 135 145 150
   Claimed in current year but earned
   in prior years
220 220 85 150 165 180 195 210
   Earned in current year but carried
   back to prior years
19 7 11 4 11 12 13 14
   Total expenditure 349 318 163 274 306 327 353 374

Estimates Projections1


2001 2002 2003 2004 2005 2006 2007 2008

($ millions)
Scientific research and experimental development investment tax credit
   Earned and claimed in current year 1,800 1,860 1,755 1,770 1,755 1,900 2,060 2,235
   Claimed in current year but
   earned in prior years9
495 480 610 930 1,010 1,095 1,185 1,285
   Earned in current year but carried
   back to prior years
89 96 88 94 93 95 97 98
   Total expenditure 2,384 2,436 2,453 2,794 2,858 3,090 3,342 3,618
Write-off of capital assets before available for use n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Apprenticeship Job Creation Tax Credit10 145 200 205
Small Business
Deduction of allowable business investment losses11 35 35 25 21 23 28 31 33
Low tax rate for small businesses12 3,650 3,610 3,440 3,305 3,560 3,940 4,250 4,420
Accelerated rate reduction for small businesses13 50 65 35 7
Non-taxation of provincial assistance for venture investments in small businesses n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
International
Exemption from Canadian income tax of income earned by non-residents from the operation of a ship or aircraft in international traffic n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Exemption from tax for international banking centres n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Exemptions from non-resident withholding tax14
   Dividends 340 325 400 590 505 625 685 720
   Interest
      On deposits 400 185 135 110 120 120 115 120
      On long-term corporate debt 195 170 195 365 260 260 255 260
      Other15 220 330 415 260 310 310 305 310
   Rents and royalties
      Copyright royalties 36 29 43 31 36 38 40 42
      Rents and royalties for the use
      of, or right to use, other
      property
115 125 91 90 105 110 115 125
      Research and development
      royalties
3 4 S S S S S S
      Natural resource royalties S S S S S S S S
      Rents from real property S S S S S S S S
   Management fees 74 70 64 65 73 76 79 82
   Estate or trust income 10 18 4 11 12 13 13 14

Estimates Projections1


2001 2002 2003 2004 2005 2006 2007 2008

($ millions)
Non-taxation of life insurance companies’ world income n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Tax exemption on income of foreign affiliates of Canadian corporations n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Sectoral Measures
Farming
Cash-basis accounting n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Deferral of income from destruction of livestock S S S 4 S S S S
Deferral of income from grain sold through cash purchase tickets16 -18 14 S S 14 S S S
Flexibility in inventory accounting n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Agricultural cooperatives17 30 30 30
Resource
Corporate mineral exploration tax credit18 S 12 21 26 35 46
Deductibility of contributions to a qualifying environmental trust S S S S S S S S
Earned depletion19 45 21 14 28 38 38 33 30
Net impact of the resource allowance and the non-deductibility of Crown royalties and mining taxes20 285 360 365 395 420 225 25
Tax rate on resource income21 -85 -210 -250 -595 -680 -335 -40
Transitional arrangement for the Alberta Royalty Tax Credit22 S S 3 5 S S
Other Sectors
Exemption from branch tax for transportation, communications, and iron ore mining corporations n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Film or video production services tax credit23 81 77 110 115 120 130 135 140
Low tax rate for credit unions24 79 80 69 67 75 82 85 83
Manufacturing and processing allowance25 1,520 1,130 470 75
Surtax on the profits of tobacco manufacturers26 -80 -75 -75 -55 -55 n.a. n.a. n.a.

Estimates Projections1


2001 2002 2003 2004 2005 2006 2007 2008

($ millions)
Other Measures
Deductibility of countervailing and anti-dumping duties n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Deductibility of earthquake reserves 7 5 5 5 5 6 6 6
Deferral through use of billed-basis accounting by professional corporations n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Holdback on progress payments to contractors27 20 5 35 40 40 40 40 40
Interest credited to life insurance policies 66 68 76 81 82 85 89 93
Non-taxation of certain federal Crown corporations n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Memorandum Items
Mechanisms for the Integration of Personal and Corporate Income Tax
Investment corporation deduction S S S S S S S S
Refundable capital gains for investment corporations and mutual fund corporations28 520 35 55 115 130 135 140 145
Refundable taxes on investment income of private corporations29
   Additional Part I tax30 -655 -670 -800 -1,150 -1,285 -1,395 -1,490 -1,590
   Part IV tax -2,105 -1,940 -1,950 -1,965 -2,140 -2,310 -2,465 -2,585
   Dividend refund 4,145 3,805 3,265 3,910 4,260 4,600 4,910 5,145
   Net expenditure 1,385 1,195 515 795 825 895 955 970
Expenses Incurred to Earn Income
Deduction for intangible assets n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Deductibility of provincial royalties (joint venture payments) for the Syncrude project (remission order)31 n.a. n.a. n.a.
Loss Offset Provisions
Capital loss carry-overs
   Net capital losses carried back32 585 1,425 465 210 205 250 285 310
   Net capital losses applied to
   current year
305 190 320 440 420 445 465 475
Farm and fishing loss carry-overs 22 18 18 23 20 22 23 22

Estimates Projections1


2001 2002 2003 2004 2005 2006 2007 2008

($ millions)
Non-capital loss carry-overs
   Non-capital losses carried back 2,840 2,000 1,900 1,185 1,230 1,415 1,575 1,715
   Non-capital losses applied to
    current year
2,995 3,385 3,060 3,205 3,190 3,315 3,405 3,280
Other
Non-resident-owned investment corporation refund33 285 420 135
Partial deduction of meals and entertainment expenses 270 275 280 305 335 370 385 365
Patronage dividend deduction 240 390 330 355 405 440 455 435

* The elimination of a tax expenditure would not necessarily yield the full tax revenues shown in the table. See the publication Tax Expenditures: Notes to the Estimates/Projections, published in 2004 and available on the Department of Finance website (www.fin.gc.ca), for a discussion of the reasons for this. [Return]

Notes:

1

Unless otherwise indicated in the footnotes, changes in the projections from those in last year’s edition of this document as well as variations from year to year result from changes in the explanatory economic variables upon which the projections are based. These changes and variations also reflect the availability of new data and improvements to the methodology used to derive the estimates/projections. Estimates and projections reflect the impact of the reduction in the general corporate income tax rate to 27 per cent on January 1, 2001, 25 per cent on January 1, 2002, 23 per cent on January 1, 2003, 21 per cent on January 1, 2004, and 20.5 per cent on January 1, 2008. The corporate surtax, which raises these rates by 1.12 percentage points, will be eliminated on January 1, 2008.

2

Donations in 2001 were significantly higher than the historical average.

3

The increase observed for 2004 reflects the availability of new information compiled from corporate income tax returns filed for the 2004 tax year.

4

The Federal Accountability Act prohibits political contributions from corporations. Accordingly, this tax expenditure will be zero after 2006.

5

Increases for 2004 and later years reflect a significant improvement in industry performance in 2004.

6

The estimate for 2001 has been revised downward relative to last year to reflect improvements in methodology and the impact of the partial inclusion of capital gains on the value of the refundable capital gains for investment and mutual fund corporations. The lower amount in 2002 reflects an estimated decrease in capital gains as well as the reduction in the corporate income tax rate. For the most part, the lower amounts in 2002 and 2003 are due to a decrease in capital gains resulting from declines in the market value of technology stocks.

7

The amount of this tax expenditure can fluctuate significantly from year to year depending on the amount of advertising expenses claimed.

8

Cyclical investments in oil and gas projects explain the downward trend from 2001 to 2003.

9

The large amounts for 2004 to 2007 relative to last year’s estimates reflect the availability of preliminary data for 2004, which shows a substantial increase in the profitability of large firms engaged in scientific research and experimental development activities allowing them to use credits earned in previous years.

10

This measure was introduced in the 2006 budget (see the "What’s New in the 2006 Report" section for more details).

11

The amount of this tax expenditure can fluctuate from year to year depending on the amount of current-year losses and the availability of income against which to apply these losses.

12

The reduction in the tax expenditure from 2001 to 2004 results from reductions in the benchmark rate. Projections reflect the increase in the amount of income eligible for the small business deduction (from $200,000 in 2002 to $400,000 in 2007) and the decrease in the small business tax rate from 12 per cent in 2007 to 11.5 per cent in 2008, followed by an additional half-point reduction, to 11 per cent, in 2009 announced in the 2006 budget. Methodological improvements have resulted in higher tax expenditures in all years compared to the 2005 publication.

13

This measure was announced in the 2000 budget and became effective January 1, 2001. On that date the general federal corporate income tax rate on income between $200,000 and $300,000 earned by a Canadian-controlled private corporation from an active business carried on in Canada was reduced to 21 per cent. The lower rate on the general income of small businesses and the change in the general federal corporate income tax rate effective January 1, 2001, only partially affect the estimate for tax year 2001 since many firms reporting income in the 2001 tax year earned a portion of that income in the 2000 calendar year, before the rate reductions were introduced. Subsequent declines in the tax expenditure are a result of the reduction in the general corporate income tax rate and the increase, announced in the 2003 budget, in the amount of income eligible for the small business deduction. This measure was effectively eliminated on January 1, 2004, when the general corporate income tax rate was reduced to 21 per cent. Some tax expenditure occurs in 2004, however, as many firms reporting income in the 2004 tax year earned a portion of that income in the 2003 calendar year.

14

Estimates and projections were computed on the basis of an analysis of payments to non-residents and withholding tax collections available for 1997 to 2004. Significant variations from last year's estimates and projections are due mainly to revised and new data, as well as to specific methodological changes that were adopted to address certain deficiencies identified with the data.

15

This category includes interest paid to non-resident persons or organizations that would be exempt from income tax in Canada were they residents in Canada. Also included is interest paid under certain securities-lending arrangements exempt under subparagraph 212(1)(b)(xii) of the Income Tax Act, and interest exempt under certain other domestic and treaty provisions.

16

Projections are calculated using a historical average growth rate. Since tax expenditures are estimated on a cash-flow basis, an increase in the balance of uncashed grain tickets represents additional income that is being deferred and results in a positive tax expenditure. A decrease in the balance of uncashed grain tickets indicates that less income is being deferred and results in a negative tax expenditure. The tax expenditure estimates and projections are volatile over time since a small number of corporations are affected in a very specific sector. Estimates and projections are based on data obtained from Statistics Canada.

17

This measure will apply only to patronage dividends paid after 2005. See the "What’s New in the 2005 Report" section in the 2005 Tax Expenditures and Evaluations publication for further details.

18

This credit was introduced in the 2003 budget and phased in starting at 5 per cent in 2003, 7 per cent in 2004 and 10 per cent in subsequent years. In the prior years, tax expenditure estimates for this credit were based primarily on exploration estimates. The projections have now been modified to incorporate actual tax collection information for 2003 and 2004. Cost estimates include the value of credits used in the year, whether they were earned in the current year or carried forward from a previous year, and credits carried back to a previous year in the current year’s tax return.

19

Additions to earned depletion pools were eliminated as of January 1, 1990. Determination of the tax expenditure reflects projected use of the existing earned pools.

20

The tax expenditure is calculated as the revenue cost of the resource allowance net of Crown royalties and provincial mining taxes. Over a five-year period beginning in 2003, the resource allowance is being phased out and a deduction for Crown royalties and mining taxes phased in, so that by 2007, this tax expenditure will be removed. See the technical paper "Improving the Income Taxation of the Resource Sector in Canada" (Department of Finance, March 2003) for further details. Costs for 2007 relate to companies that do not have a December 31 year-end for which the 2007 tax year includes a portion of 2006 activities.

21

Budget 2003 announced the extension to resource income of the lower general corporate income tax rate, to be phased in over five years beginning in 2003. Although the rate difference no longer exists in 2007, there are still costs associated with 2006 rates for companies that do not have a December 31 year-end and the 2007 tax year includes some income earned in 2006.

22

The Alberta government has announced that the Alberta Royalty Tax Credit (ARTC) will be eliminated as of January 1, 2007. Costs for the federal transitional measure will continue into 2007 and 2008 because some credit amounts related to 2006 will only be received in 2007, and for companies that do not have a December 31 year-end, some amounts received in 2007 will fall into their 2008 taxation year.

23

Projections for 2003 and subsequent years reflect the increase of the rate of the credit from 11 per cent to 16 per cent.

24

The increases from last year’s projections for 2006 and 2007 are due to an increase in the growth rate of taxable income. This tax expenditure also includes credit unions’ deposit insurance corporations, which receive similar tax treatment to credit unions.

25

Although this tax expenditure was eliminated on January 1, 2004, when the general corporate income tax rate was reduced to 21 per cent, many firms reporting income in the 2004 taxation year earned a portion of that income in the 2003 calendar year.

26

The decrease in this tax expenditure after 2003 is due to the decrease in tobacco manufacturers’ profits. For confidentiality reasons, projections for 2006 to 2008 are not published.

27

The amount of this tax expenditure can fluctuate significantly from year to year depending primarily on the level of construction activity. Therefore, it is projected at its historical average.

28

For the most part, the large declines in 2002 and 2003 are due to a decrease in capital gains resulting from declines in the market value of technology stocks.

29

Refundable tax provisions of the corporate income tax system provide some integration of the corporate and personal income tax regimes. For more information about these measures, see the 2004 publication Tax Expenditures: Notes to the Estimates/Projections.

30

This item includes the additional 62⁄3 per cent refundable tax on investment income as well as the Part I tax paid on investment income in excess of the benchmark rate. Increases in this tax expenditure result from the increase in the difference between the Part I tax on investment income and the benchmark rate.

31

The cost of the Syncrude Remission Order ("Order Respecting the Remission of Income Tax for the Syncrude Project," P.C. 1976-1026,
May 6, 1976 [C.R.C. 1978, Vol. VII, c. 794]) is published annually in the Public Accounts of Canada (ISBN 0-660-177792-7). The order expired on December 31, 2003.

32

Large values in 2001 and 2002 reflect, for the most part, the capital losses recorded in these two years resulting from declines in the market value of technology stocks.

33

This measure was repealed in 2000. To allow for an orderly restructuring of their operations, however, existing non-resident-owned investment corporations were entitled to retain their status until the end of their last tax year that began before 2003.

Table 3
GST Tax Expenditures*


  Estimates Projections
 

  2001 2002 2003 2004 2005 2006 2007 2008

  ($ millions)
Aboriginal Self-Government                
Refunds for Aboriginal self-government1,2 S S S S S S S S
Business                
Exemption3 for domestic financial services n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Exemption for ferry, road and bridge tolls4 5 10 10 5 5 5 5 5
Exemption and rebate for legal aid services 25 25 25 25 30 25 25 30
Non-taxability of certain importations5 n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Rebates for foreign visitors6 80 85 85 70 80 70 20
Small suppliers’ threshold 155 165 170 180 195 180 160 170
Zero-rating7 of agriculture and fish products and purchases S S S S S S S S
Zero-rating of certain purchases made by exporters S S S S S S S S
Charities and Non-Profit Organizations                
Exemption for certain supplies made by non-profit organizations n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Rebates for registered charities1 240 255 270 280 295 290 280 295
Rebates for non-profit organizations1 60 60 70 70 75 75 70 75
Education                
Exemption for education services (tuition)4 395 435 470 505 535 525 515 545
Rebates for book purchases made by qualifying public institutions8 30 30 30 30 30 30 30 35
Rebates for colleges1 80 85 85 80 80 80 80 80
Rebates for schools1 375 380 380 400 420 410 400 420
Rebates for universities1 180 205 240 260 275 270 260 270
Health Care                
Exemption for health care services4 325 445 480 505 525 515 510 555
Rebates for hospitals1 390 395 425 465 490 480 465 485
Zero-rating of medical devices4 120 135 145 150 160 155 155 165
Zero-rating of prescription drugs4 430 465 500 535 565 555 545 575
Households                
Exemption for child care and personal services4 130 130 130 125 130 130 125 135
GST/HST credit9 3,130 3,250 3,415 3,460 3,545 3,620 3,660 3,720
Zero-rating of basic groceries4 3,270 3,515 3,650 3,800 4,015 3,935 3,855 4,095

  Estimates Projections
 

  2001 2002 2003 2004 2005 2006 2007 2008

  ($ millions)
Housing                
Exemption for sales of used residential housing and other personal-use real property n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Exemption for residential rent (long-term)4 1,275 1,355 1,420 1,445 1,515 1,490 1,465 1,565
Rebates for new housing10 640 785 835 925 990 1,015 970 1,050
Rebates for new residential rental property 40 45 50 60 60 65 60 60
Municipalities                
Exemption for municipal transit4 85 105 105 160 170 165 165 175
Exemption for water and basic garbage collection services4 160 180 185 230 245 240 235 250
Rebates for municipalities1,11 700 725 805 1,435 1,510 1,480 1,435 1,500
Memorandum Items                
Recognition of Expenses Incurred to Earn Income                
Rebates to employees and partners12 105 105 115 115 120 110 100 105
Other                
Exemption for quick method accounting 200 205 215 230 245 240 230 245
Partial input tax credits for meals and entertainment expenses13 120 125 135 160 180 170 155 155

* The elimination of a tax expenditure would not necessarily yield the full tax revenues shown in the table. See the publication Tax Expenditures: Notes to the Estimates/Projections, published in 2004 and available on the Department of Finance website (www.fin.gc.ca), for a discussion of the reasons for this. [Return]

Notes:

1

The public sector body rebates are based on Canada Revenue Agency administrative data for the years up to and including 2004. The projections are based on the National GST Model of the Department of Finance.

2

These refunds are paid to Aboriginal governments that have an agreement providing for a GST/HST (harmonized sales tax) refund for goods and services acquired for self-government activities.

3

Final consumers and businesses pay no tax on exempt goods and services. Vendors, however, are not entitled to claim input tax credits to recover the GST/HST paid on inputs to these products.

4

The National GST Model used to generate these estimates is based on the 2002 national input-output tables from Statistics Canada and the latest release of the National Income and Expenditure Accounts.

5

Certain importations are tax-free including, for example, duty-free personal importations by Canadian travellers.

6

The Visitor Rebate Program is proposed to be eliminated effective April 1, 2007.

7

Final consumers and businesses pay no tax on zero-rated goods and services. Vendors of zero-rated products are entitled to claim input tax credits to recover the GST/HST paid on inputs to these products.

8

Book rebates are now taken directly from administrative data for 2001 to 2004.

9

Based on personal income tax data.

10

Estimates for the housing rebate are based on information provided by Statistics Canada.

11

The rebate rate for municipalities increased from 57.14 per cent to 100 per cent effective February 1, 2004.

12

This item includes the apprentice vehicle mechanics’ tools deduction.

13

Based on tax expenditure estimates and projections reported for the personal and corporate income tax systems.

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