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$10/day in 210+ countries and destinations.

To add TravelPass, text the word TRAVEL to 4004 or click here

With TravelPass

Get unlimited talk text and data* in 210+ countries and destinations. Once added, you'll only be charged on the days you send or receive a call, send texts or use data on your device while abroad, so there's no need to remove it when you return.

TravelPass can be used in 210+ countries and destinations .

If you choose not to add TravelPass or travel to a country not included in TravelPass you'll be charged Pay as You Go rates.

Back to International Travel plans

$10 /line per day. Plus taxes and fees.

$5/line in Canada and Mexico.

Roaming in Canada and Mexico is included with Unlimited Plus, Unlimited Welcome, and other Unlimited plans.

Get a TravelPass day on us every month on select Unlimited plans.

What's included:

Unlimited data

Unlimited calls

Unlimited texts

Your domestic data allowance*

*After the first 2GB of daily session enjoy unlimited 3G data. You can purchase additional high speed data for the remainder of your session. World device is required. Must be on a qualifying plan.

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Find the best plan for your international trip.

TravelPass days on us.

Get 2 free TravelPass days per year when you sign up to the Verizon Visa Credit Card.

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Have questions? We’ve got answers.

How does travelpass work and when will i be charged for it.

Here's how TravelPass works. After you add TravelPass to your mobile phone line:

• A 24-hour TravelPass session starts automatically when you use your phone in a TravelPass country (e.g., make or answer a phone call, send a text or use data).
• You're only charged for the days that you use your device in the TravelPass country.
• You must turn on cellular data or data roaming when you go to the TravelPass country.
• App content refreshing (e.g., Weather apps, Fitness Tracker)
• Syncing (e.g., email)
• Device or app software updates

2 hours after the session starts we send you a text letting you know when your 24-hour TravelPass session ends. Using your device after that session starts a new session.

Which countries can I call with TravelPass?

With TravelPass, you can call within the country you're visiting and you can call back to the US. If you want to call a different country, add an International Long Distance Plan to your line in My Verizon website or the My Verizon app. If you don't add an international long distance plan you'll be charged international long distance pay per minute rates for these calls.

Can I use Wi-Fi calling with TravelPass?

Wi-Fi calling isn't included with TravelPass. Wi-Fi calling to a country other than the US is charged international long distance rates regardless of whether or not you have an international travel plan.

Do I have to opt in every day to use TravelPass?

No, you don't need to opt in every day. Add TravelPass once and it stays on your line so you're all set for your next trip. You're only charged for the days that you use your device in a TravelPass country . There's no charge when you're in the US.

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Calling a country outside the us, international services support.

While in the US: (800) 711-8300

Travelling outside the US: 1 (908) 559-4899

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If a toll-free number is not available for the country you are in, please dial (908) 559-4899 (toll charges will apply).

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Update April 12, 2024

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Routine:  6-8 weeks*

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*Consider the total time it will take to get a passport when you are booking travel.  Processing times only include the time your application is at a passport agency or center.

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• Processing times + mailing times = total time to get a passport

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Hong kong special administrative region travel pass.

This webpage sets out the eligibility criteria and application procedures for persons who wish to apply for the Hong Kong Special Administrative Region Travel Pass Scheme.

The aim of the Travel Pass Scheme is to enhance the mobility of business travellers by facilitating bona fide frequent visitors to the Hong Kong Special Administrative Region (HKSAR). The Travel Pass is a machine readable document with 32 pages. It is valid for 3 years and good for multiple entries to the HKSAR for a stay of 2 months each trip. The holder of a Travel Pass will be allowed to use Hong Kong resident counters and the immigration clearance procedures will be simplified.

Frequent visitors who hold valid passports and are eligible to come to the HKSAR without a visa or entry permit for visit purpose may apply for HKSAR Travel Pass. Applicants should have genuine needs to visit the HKSAR frequently, and have come for visits trouble-free on 3 or more occasions (other than return from side trips to the Mainland of China or the region of Macao) in the 12-month period immediately preceding the application, or can satisfy the Director of Immigration that their visits may bring substantial benefits to the HKSAR. The Director of Immigration reserves the right not to issue a HKSAR Travel Pass even if the criteria stated above are fulfilled.

Applicant should complete the application form ( ID 888 ) in Chinese or English, and properly sign it. The name and other personal particulars in the application form must be identical to those appearing on applicant’s valid passport.

Application form can be obtained free of charge from the  Information and Liaison Section of the Immigration Department , Chinese diplomatic and consular missions  and Hong Kong Economic and Trade Offices overseas . The form can also be downloaded here .

The nomination of a referee or major business contact in the HKSAR is necessary to assist the Immigration Department to process the application. This will avoid unnecessary delay.

Applicant should complete the application form ( ID 888 ) in block letters with a recent photograph affixed on it and enclosed with:

• a photocopy of applicant’s valid passport showing the personal particulars of the holder, nationality, re-entry visa to the country of residence (if applicable), date of issue and expiry of the valid travel document, and the records of his/her latest three visits to the HKSAR/landing slips in the last 12 months;
• one additional identical photograph of applicant; and
• letter from applicant’s employing company supporting his/her application and background information of the company, and supporting letter from applicant’s major Hong Kong business contact if visits are for business purposes.

Applicant may be required to submit further supporting documents and information in connection with the application when necessary.

Online Submission

Click here for online submission of application and uploading of supporting documents.

Other Means of Submission

Completed application forms, i.e. ID 888 , and all supporting documents may also be submitted to the Immigration Department by post, in person or through his/her referee in the HKSAR to the following address:

Other Visas and Permits Section Immigration Department 7/F, Immigration Tower 7 Gloucester Road Wan Chai, Hong Kong

Underpaid mail items will not be accepted by the Immigration Department. For proper delivery of your mail items, please ensure your mail items bear sufficient postage with return address before posting. ( Details )

Once the receipt of application has been acknowledged, applicants can enquire their application status here  or through the 24-hour telephone enquiry system at (852) 3160 8663.

Applicant may collect his/her Travel Pass either in person or authorise a representative to collect it on his/her behalf. Upon collection, the applicant or his/her authorised representative must produce his/her original valid passport for inspection if this has not been done when he/she submits the application. Applicant must use his/her Travel Pass together with his/her valid passport for arrival and departure clearance at control points in the HKSAR.

The prescribed fee should be paid upon collection of the Travel Pass. It is payable in cash, by EPS, by Octopus or by Faster Payment System (FPS), or by cashier order or bank draft drawn on a bank in the HKSAR or crossed cheque from a bank account in the HKSAR in Hong Kong currency either to 'The Government of the Hong Kong Special Administrative Region' or 'The Government of the HKSAR'.

• Application forms relating to HKSAR Travel Pass

How much does it cost to process a US passport in 2024?

Before making travel plans, it’s best to check that your passport hasn’t expired. how much does it cost to renew or apply for an american passport in 2024.

The passport is an important document as it serves as proof of identity , and is necessary to travel outside the United States. Now that peak travel season is approaching, it is useful to check if your passport is still valid, and to know how much you need to pay to renew it. First-time applicants should also consider the cost of getting a passport and add it to their travel budget .

According to the usa.gov website , to be eligible to apply for a passport a person must be a U.S. citizen by birth or naturalization or a qualified non-US citizen national.

What is needed to apply for a US passport?

If you are applying for your passport for the first time, you must do so in person at a passport acceptance center . This procedure cannot be done online or by mail. The requirements for a person applying for an American passport for the first time are the following:

Application (Form DS-11)

You can complete the DS-11 form online and print it. You can also download it and complete it by hand. Another option is to visit your local passport acceptance center or regional agency to request the form.

It is important that you not sign the DS-11 form until you are at your appointment and the passport acceptance officer tells you to do so .

Personal documents

These include original proof of citizenship, an acceptable photo ID, and a photocopy of your citizenship document and photo ID.

Passport photo and fee

You must also submit a photograph that follows the guidelines set by the Office of Consular Affairs, as well as pay the processing fee.

It’s true – we're thinking about passports all day, every day. And while we don’t expect you to do the same, it’s a good idea to know your passport’s expiration date and set a calendar reminder to renew at least six months before it expires. 😊📅✅ pic.twitter.com/SvXZrZpYg2 — Travel - State Dept (@TravelGov) April 16, 2024

READ ALSO: Allergy season is here

Prices of the American passport in 2024

To apply for a passport for the first time, you need to cover the cost of the application as well as the execution fee.

First-time passport fees for adults over 16 years of age are as follows:

• Passport Book: $130 (application) and $35 (execution fee)
• Passport Card: $30 (application) and  $35 (execution fee)
• Passport Book and Card: $160 (application) and $35 (execution fee)

The passport prices for children and adolescents under 16 years of age are:

• Passport Booklet: $100 (application) and $35 (execution fee)
• Passport Card: $15 (application) and $35 (execution fee)
• Passport Book and Card: $115 (application) and $35 (card)

READ ALSO: The average tax refund amount in 2024

For passport renewal , the passport book alone costs $130, while renewing a passport card costs only $30 . Opting for both will cost $160. The execution fee is not paid in the renewal process.

To speed up the processing of your passport, you must pay for the expedited service, which has an extra cost of $60. If you have questions, you can consult the fee calculator on the State Departments website.

Commission offers 35,500 DiscoverEU free travel passes to young people

Starting this summer, thousands of young people will once again travel around Europe by train for free thanks to the latest call of the DiscoverEU programme. Today at 12:00 CET during the  European Youth Week  buzzing with  activities , the Commission launched the latest DiscoverEU application round. It will end on Tuesday 30 April at 12:00 CET.

In total, 35,500 travel passes are available. To get one, young people born between 1 July 2005 and 30 June 2006 can do a quiz with five questions about the EU and one additional question on the  European Youth Portal . Successful applicants will get a free rail pass to travel in Europe for up to 30 days between 1 July 2024 and 30 September 2025.

The call is open to applicants from the European Union and countries associated to the  Erasmus+ programme  including Iceland, Liechtenstein, North Macedonia, Norway, Serbia and Türkiye. Ticket holders can plan their own routes or be inspired by existing ones. For example, they can discover a  route  launched last year, which focuses on cities and places making the European Union ‘beautiful, sustainable and inclusive' in line with the principles of the  New European Bauhaus .

Participants can also benefit from the  DiscoverEU Culture Route  an initiative of the 2022 European Year of Youth that combines various cultural destinations including architecture, music, fine art, theatre, fashion and design. Participants can visit the  European Capitals of Culture  which are on the  UNESCO World Heritage List ,   European Heritage Label  sites, or  Access City Award  label locations, which are cities that have gone above and beyond to become more accessible to everyone.

DiscoverEU is much more than just a ticket. Participants will also receive a  discount card  with over 40,000 discount possibilities on public transport, culture, accommodation, food, sports and other services in eligible countries. Additionally,  Erasmus+ National Agencies  organise pre-departure information meetings, and national agencies across all Erasmus+ countries prepare  DiscoverEU Meet-ups , learning programmes lasting from one to three days.

Social inclusion is a top priority of the Erasmus+ programme, so participants with disabilities or health issues receive support on their journeys. Since October 2022, the Erasmus+ National Agencies have implemented the  DiscoverEU Inclusion Action , allowing organisations working with young people with fewer opportunities to apply for a grant. This action provides extra support to participants, such as extra funding and the possibility to travel with accompanying persons. More than 250 projects have been awarded by the Erasmus+ National Agencies since the first call in October 2022, and two calls of the Inclusion Action are taking place in this year.

While DiscoverEU encourages sustainable travel by rail,  special arrangements  are available for young people from outermost regions, Overseas Counties and Territories, remote areas and islands.

The Commission launched  DiscoverEU  in June 2018 following a preparatory action from the European Parliament. It is integrated into the  Erasmus+ programme 2021-2027 .

Since 2018, more than 1 million candidates have applied for 284,000 available travel passes. According to the latest post-travel survey, 72% of candidates declared it to be the first time travelling out of their country of residence by train. For many, it was also the first time they travelled without parents or accompanying adults, and the majority indicated an increased sense of independence. Over two-thirds said that they would not have been able to finance their travel pass without DiscoverEU.

The DiscoverEU experience has given young people a better understanding of other cultures as well as European history and improved their foreign language skills. Participants are invited to become DiscoverEU Ambassadors to champion the initiative. The  # DiscoverEU Official group  has more than 96,000 members where young travellers can contact each other to share experiences and tips.

To apply, eligible candidates need to complete a multiple-choice quiz on general knowledge about the European Union and other EU initiatives targeting young people. The Commission will rank applicants on the basis of their responses. The Commission will offer travel passes to applicants following their ranking up to the limit of available tickets.

For More Information

European Youth Portal

DiscoverEU is a fantastic opportunity for young people who want to explore Europe, discover places and meet new people. I am happy to launch this spring application round during the exciting European Youth Week. I wish the best of luck to all applicants!

Iliana Ivanova, Commissioner for Innovation, Research, Culture, Education and Youth

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Passing Thru Travel

10 Visa and Passport Tips for Hassle-Free Travel 2024

Posted: March 12, 2024 | Last updated: March 12, 2024

Embarking on international travel demands meticulous planning, particularly in navigating the often complex landscape of visas and passports. This guide is your essential compendium, offering in-depth insights and strategic tips to streamline your travel documentation process. Tailored for novice and seasoned travelers, it ensures that your focus remains on the excitement of your journey rather than the nuances of bureaucracy.

1. Understanding Visa Types and Their Specific Requirements

Each visa type demands a unique set of documents and prerequisites. Tourist visas, generally the most straightforward, still require proof of return tickets, accommodation, and sometimes a detailed itinerary. Business visas may need an invitation from a host company, while student and work visas often have more stringent requirements, including proof of enrollment or employment.

Transit visas, overlooked yet crucial for certain layovers, must be considered to avoid unexpected detours. Begin your application process early, as embassies and consulates can take weeks, if not months, to process requests.

Insider’s Tip: Familiarize yourself with the different types of visas—tourist, business, transit, student, and work visas—and understand the specific requirements for each. This knowledge can significantly influence the success of your application and the smoothness of your travel plans.

2. Navigating Passport Validity and Blank Page Requirements

The overlooked detail of passport expiration can derail your travel plans. Regularly check your passport’s expiry date and renew it well in advance if necessary. Countries requiring a certain number of blank pages in your passport do so for immigration stamps. Falling short on this requirement can result in denied boarding or entry.

Keep in mind that renewal times can vary, and expedited services, while available, come with additional costs. This is a critical step in your travel preparation, so make it a priority in your planning stages.

Insider’s Tip: Ensure your passport has sufficient validity — many countries require it to be valid for at least six months beyond your travel date. Also, check for blank pages; some countries require a specific number for entry and exit stamps.

3. Visa Application: Timing and Documentation

Timing is everything in visa applications. Start gathering required documents—such as photographs, travel insurance, financial statements, and any necessary letters or invitations—as early as possible. Be aware of holidays and peak periods, as these can affect processing times.

Online visa applications have simplified the process for many countries, but always have hard copies of essential documents when traveling. A common pitfall is underestimating the time it takes for visa processing; each country has its own timeline, and it’s prudent to allow extra time for any unforeseen complications.

Insider’s Tip: Apply for your visa as soon as your travel dates are confirmed. Late applications can lead to stressful delays or, worse, trip cancellations.

4. Health and Vaccination Documentation

Health documentation is increasingly becoming a staple in international travel. Countries in Africa and South America, for instance, may require proof of Yellow Fever vaccination. COVID-19-related health documentation has also become a norm. Always carry a physical copy of your vaccination records and any other required health documents.

The World Health Organization (WHO) offers a standardized ‘Yellow Card’ that shows vaccination history and is recognized worldwide. Not adhering to these requirements can result in being denied entry, so it’s critical to understand and comply with these health mandates.

Insider’s Tip: Some countries require proof of vaccination against specific diseases. Keep a record of your vaccinations and check the health requirements of your destination country.

5. Understanding Visa Waiver Programs and e-Visas

Many countries have agreements allowing certain nation citizens to enter without a traditional visa. For instance, the Schengen Area in Europe allows travelers from certain countries to enter visa-free for short stays.

Similarly, e-Visas, available through online applications, offer a streamlined process for obtaining travel authorization. These digital visas save time and reduce paperwork but always confirm the specific entry requirements, as they can vary even within visa waiver programs.

Insider’s Tip: Check if the country you visit has a visa waiver program or offers e-Visas, as these can significantly simplify the travel process.

6. Dealing with Visa Denials and Appeals

A visa denial can be disheartening, but it’s not always the end of the road. Embassies usually provide reasons for denial, which you should address in subsequent applications. Some countries offer an appeal process, while others require you to wait a certain period before reapplying.

Understanding the specific protocol of the country you’re applying to is crucial. Ensure your reapplication or appeal addresses all the concerns raised initially. Sometimes, seeking the assistance of a visa consultant or an immigration lawyer can provide clarity and improve your chances in complex cases.

Insider’s Tip: In case of a visa denial, understand the reasons provided and the process for an appeal or reapplication, if applicable.

7. Passport Safety and Copies

Your passport is your most valuable document when traveling abroad. Keep it secure in a hotel safe or a secure, hidden compartment in your luggage. Having copies of your passport (the page with your personal information and any relevant visa pages) is crucial in emergencies.

Store a digital copy in a secure cloud service and email a copy to yourself and a trusted contact back home. In the unfortunate event of losing your passport, these copies will be instrumental in proving your identity and facilitating the replacement process at your embassy or consulate.

Insider’s Tip: Keep your passport safe at all times and carry physical and digital copies in case of loss or theft.

8. Cultural Sensitivity and Local Laws

Cultural awareness is a sign of respect and can affect your entry into a country. Some nations have strict dress codes or norms that, if not adhered to, can lead to issues at immigration. Familiarize yourself with these aspects to avoid unintentional offenses. Additionally, understanding local laws is crucial.

For example, countries in the Middle East have stringent drug laws, and carrying certain prescription medications without proper documentation can lead to serious legal troubles.

Insider’s Tip: Research your destination’s cultural norms and local laws, as these can sometimes impact visa and entry policies.

9. Travel Insurance and Visa Requirements

Travel insurance is often a visa requirement, especially for countries in the Schengen Area. This insurance should cover medical expenses, trip cancellations, lost luggage, and repatriation. Check the specific coverage requirements of your destination country and keep a copy of your insurance policy with your travel documents. Not only is it necessary for some visa applications, but it’s also a prudent safeguard against unforeseen events during your travels.

Insider’s Tip: Some countries require proof of travel insurance for visa issuance. Ensure your policy meets the minimum coverage requirements.

10. Consulate and Embassy Assistance

Embassies and consulates can assist with a range of issues — from lost passports to legal troubles. Before traveling, note the address and contact details of your country’s diplomatic missions in the destination country.

In case of an emergency, such as a lost or stolen passport, political unrest, or natural disasters, they can provide crucial support and guidance. It’s also wise to inform them of your travel plans, particularly if traveling to regions with heightened security risks.

Insider’s Tip: Know the location and contact details of your country’s embassy or consulate in your destination country. They can be invaluable in emergencies.

The Bottom Line

Successful and hassle-free travel hinges on your preparedness, especially regarding visas and passports. By following these tips, you’re paving the way for a journey of ease and enjoyment. Equip yourself with this knowledge, and step confidently into your next journey, knowing you’ve covered every essential detail.

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The post 10 Visa and Passport Tips for Hassle-Free Travel 2024 republished on Passing Thru with permission from The Green Voyage .

Featured Image Credit: Shutterstock / Eviart.

For transparency, this content was partly developed with AI assistance and carefully curated by an experienced editor to be informative and ensure accuracy.

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2024 NFL draft in Detroit: Everything you need to know before you go

The 2024 NFL draft is in Detroit on April 25-27, as you probably have heard by now. If you're traveling to Detroit for the draft , here's a guide to make your draft experience easy and unforgettable.

Information on registration, parking, travel, street closings, and draft day activities are all below.

When is the 2024 NFL draft?

The 2024 NFL draft is from April 25-27 in Detroit, spanning from Campus Martius to Hart Plaza in downtown with additional events in Beacon Park, Capitol Park, Grand Circus Park, Harmonie Park, and along Woodward Avenue.

2024 NFL draft registration

If you still have not signed up for the free draft day experience, there's still time to register using the NFLOnePass app or online through the website .

Registering for the event only guarantees you the NFL draft footprint in downtown Detroit. You must buy tickets separately for the actual draft theater.

Ticket packages are available for purchase for the second and third rounds starting at $950 per person — the fourth through seventh rounds start at $550 per person as well. Please be wary of potential ticket scams .

• More: Registration to attend NFL draft in Detroit now open: What you need to know

Can I still book a hotel in Detroit for the draft?

With the NFL draft just two weeks away, options are limited if you're still looking to book a place near the NFL draft in Detroit. Here's what to know .

Downtown Detroit transportation

Detroit has multiple public transport options to get around downtown. The city has a streetcar , an elevated rail system , bike share , and bus system to get you where you need to go.

That said, plan to get downtown early and be prepared to leave late. Hundreds of thousands of fans are expected to travel to Detroit over the course of the draft's three days.

• More: New service details released about Detroit public transit options

Detroit parking for 2024 NFL draft

You can pay for metered parking through Park Detroit's website or app. There are also options for private parking throughout the city.

More: Downtown Detroit parking lots to see upgrades ahead of 2024 NFL draft

Detroit road closures for 2024 NFL draft

The city will start phase three of its street closings on April 15 at midnight. This marks the halfway point of the action plan to close downtown streets to accommodate the draft day build-out.

Closed streets for phase three :

• Jefferson Avenue; Bates Street; Atwater Street
• Southbound M-10 (Lodge), full closure at West Jefferson (Exit 1A: open); Larned ramp (Exit 1B: open)

Things to do in Detroit during the 2024 NFL draft

Detroit is a city rich with museums, restaurants and activities throughout. If you're interested in exploring the area outside of the draft, you can go to the Motown Museum, the Michigan Science Center, check out golf-rich southeast Michigan , and even catch a Detroit Tigers game on April 26, 27 or 28 when they host the Kansas City Royals.

Get a souvenir while you're in the city.

More: NFL draft in Detroit: Hotels, restaurants, things to do for traveling fans

Detroit NFL draft activities

Draft day activities are from noon to 10 p.m. on Thursday and Friday. On Saturday, events go from 9 a.m. to 6 p.m.

Activities include a Pro Football Hall of Fame exhibit and an autograph signing opportunity with current and former NFL players, as well as a 40-yard dash, vertical jump, deep throw accuracy challenges, and more. There will also be a collection of Detroit-based food trucks for participants who attend.

More: Detroit City Council OKs several public, private NFL draft events

Usually, the top prospects that go at the beginning of the first round will attend the draft in person, so players such as Caleb Williams, Drake Maye, Marvin Harrison Jr., Jayden Daniels and Michigan's J.J. McCarthy could walk across the stage in the heart of downtown Detroit. There have not been any announcements yet of which prospects will be at the draft April 25.

What else is Detroit doing for the NFL draft?

Here's a list of other attractions and events planned for Detroit and the 2024 NFL draft:

• The Detroit "Hollywood-style" sign is constructed along eastbound Interstate 94. Here's how to scope it out .
• On April 25, the first night of the draft, the Lions are hosting an event for season ticket holders at Ford Field.
• Detroit has 20 painted cleat sculptures throughout the city, in an exhibit called "DCLEATED."
• Detroit City Distillery has several NFL draft events planned .
• Country star Jelly Roll is planning an intimate "Night Before" concert at Fillmore Detroit on April 24.

Follow the Detroit Free Press on Instagram ( @detroitfreepress ), TikTok ( @detroitfreepress ), YouTube ( @DetroitFreePress ), Twitter/X ( @freep ),   and  LinkedIn , and like us on Facebook ( @detroitfreepress ).

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Before you apply, we recommend that you review the various DHS trusted traveler programs, such as the TSA PreCheck® Application Program, Global Entry, NEXUS, or SENTRI, to ensure you meet the eligibility requirements and determine the best program for you.  If you travel internationally four or more times a year, consider enrolling in Global Entry.  If you take less than four international trips a year, TSA PreCheck is a great choice for domestic travelers. For more information on all of the DHS Trusted Traveler Programs use the DHS interactive  Trusted Traveler Tool .

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CBP Enhances Traveler Experience By Expanding Mobile Passport Control to All Preclearance Airport Locations

WASHINGTON— U.S. Customs and Border Protection (CBP) announced today that Abu Dhabi is the latest Preclearance location to allow U.S. citizens and select non-U.S. travelers to use the Mobile Passport Control (MPC) mobile application to clear the CBP inspection process before boarding U.S.-bound flights.

The addition of Abu Dhabi makes MPC available at all 14 Preclearance airport locations under CBP’s International Field Office, including Aruba; Bermuda; Dublin and Shannon, Ireland; Nassau, Bahamas; and Calgary, Edmonton, Halifax, Montreal, Ottawa, Toronto, Vancouver, and Winnipeg, Canada.  

“CBP is committed to the facilitation of travel and tourism to the United States,” said CBP International Operations and Advisory Directorate Executive Director Donald Conroy. “Mobile Passport Control is an important step in enhancing travelers’ arrival experience, and offers travelers additional options to expedite their entry into the U.S.”

The MPC mobile app is available to U.S. citizens, U.S. lawful permanent residents, Canadian B1/B2 citizen visitors, and returning Visa Waiver Program travelers with an approved Electronic System for Travel Authorization (ESTA) form. The app allows travelers to submit their passport and travel information in advance at designated locations with a mobile device, resulting in less congestion and more efficient processing.

The MPC mobile app can be downloaded for free from the  Google Play Store  or  Apple App Store . After downloading the app, users will be prompted to create a profile with their passport information any time prior to arriving in a CBP facility. Up to 12 profiles can be created for family members and a single household can submit a single MPC transaction. Upon arrival at participating U.S. or Preclearance locations, travelers can take a selfie for every member of the traveling group and submit their information to CBP through the MPC app without completing a paper form. Once travelers arrive in the CBP clearance area, they should look for the designated MPC queue, and then present their passports or U.S. Lawful Permanent Resident cards to the CBP officer for processing.

With travel volumes surpassing pre-pandemic levels, CBP plays a critical role in facilitating trade and travel. The MPC program was originally launched in August 2014 and is currently available at 51 locations, including 33 U.S. international airports, 14 Preclearance airport locations, and four seaports of entry. In Fiscal Year 2023, MPC was used by more than 1.8 million travelers. For more information on MPC, including user eligibility, visit the CBP MPC website .

U.S. Customs and Border Protection is the unified border agency within the Department of Homeland Security charged with the comprehensive management, control, and protection of our nation’s borders, combining customs, immigration, border security, and agricultural protection at and between official ports of entry.

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2024 Federal Budget analysis

On April 16, 2024, the Deputy Prime Minister and Minister of Finance, Chrystia Freeland, presented the government’s budget. The budget:

• increases the capital gains inclusion rate from 1/2 to 2/3, effective June 25, 2024 (up to $250,000 of annual gains for individuals will continue to benefit from the 1/2 inclusion rate)
• raises the lifetime capital gains exemption to $1.25 million and introduces a new 1/3 inclusion rate for up to $2 million of certain capital gains realized by entrepreneurs
• confirms previously announced alternative minimum tax proposals effective January 1, 2024, but softens the impact of these proposals on charitable donations
• provides design and implementation details for the clean electricity investment tax credit
• introduces accelerated capital cost allowance (CCA) for, and relief from interest deductibility limitations for debt incurred to fund the construction of, certain purpose-built rental housing
• provides immediate expensing for the cost of certain patents and computer equipment and software
• gives the Canada Revenue Agency (CRA) additional information gathering powers

This Tax Insights discusses these and other tax initiatives proposed in the budget.

Tax measures

Capital gains inclusion rate.

• Lifetime Capital Gains Exemption

Canadian Entrepreneurs’ Incentive

• Alternative Minimum Tax

Employee Ownership Trust Tax Exemption

Volunteer firefighters tax credit and search and rescue volunteers tax credit, mineral exploration tax credit for flow-through share investors.

• Canada Child Benefit

Disability Supports Deduction

Charities and qualified donees.

• Home Buyers’ Plan

Qualified Investments for Registered Plans

Deduction for tradespeople’s travel expenses, indigenous child and family services settlement, clean electricity investment tax credit, ev supply chain investment tax credit, clean technology manufacturing investment tax credit.

• Accelerated Capital Cost Allowance

Interest Deductions and Purpose-Built Rental Housing

Taxing vacant lands to incentivize construction, confronting the financialization of housing, halal mortgages, non-compliance with information requests, synthetic equity arrangements, mutual fund corporations, canada carbon rebate for small business, avoidance of tax debts, reportable and notifiable transactions penalty, manipulation of bankrupt status.

• Scientific Research and Experimental Development

International

Crypto-asset reporting, withholding for non-resident service providers, international tax reform.

• Extending GST Relief to Student Residences

GST/HST on Face Masks and Face Shields

Previously announced, personal tax measures.

The budget proposes to increase the capital gains inclusion rate from 1/2 to:

• 2/3 for dispositions after June 24, 2024 for corporations and trusts, and
• 2/3 for the portion of capital gains realized after June 24, 2024 in excess of an annual $250,000 threshold for individuals

The $250,000 annual threshold would apply to capital gains realized by an individual, either directly or indirectly via a partnership or trust, net of:

• current year capital losses
• capital losses of other years applied to reduce current year capital gains, and
• capital gains in respect of which the Lifetime Capital Gains Exemption (LCGE), the proposed Employee Ownership Trust Exemption or the proposed Canadian Entrepreneurs’ Incentive is claimed

As a result, the following rates will apply to capital gains earned by individuals in excess of the $250,000 threshold who are subject to the top marginal income tax rate (i.e. on taxable income exceeding: $355,845 in Alberta, $252,752 in British Columbia, $1,103,478 in Newfoundland and Labrador, $500,000 in the Yukon and $246,752 in all other jurisdictions).

The budget also proposes to decrease the stock option deduction to 1/3 to align with the new capital gains inclusion rate.  Individuals would continue to benefit from a deduction of 1/2 of the taxable benefit up to a combined $250,000 for both employee stock options and capital gains.

The inclusion rate for net capital losses carried forward and applied against capital gains will be adjusted to reflect the inclusion rate of the capital gains being offset.   

Transitional rules will apply to taxation years that begin before June 25, 2024 and end after June 24, 2024 such that capital gains realized before June 25, 2024 would be subject to the 1/2 inclusion rate and capital gains realized after June 24, 2024 (net of any losses) would be subject to a 2/3 inclusion rate. The $250,000 threshold will not be prorated for individuals in 2024 and will apply only against capital gains incurred after June 24, 2024.

Additional details will be provided in the coming months.   

Earning capital gains through a Canadian-controlled private corporation (CCPC)

In most jurisdictions, the increase in the capital gains inclusion rate makes it less attractive for individuals to earn capital gains in excess of $250,000 through a CCPC instead of directly. The  Appendix shows the resulting income tax deferral (prepayment) and the tax cost for an individual who realizes capital gains in excess of $250,000 and pays tax at the top tax rate.

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Lifetime Capital Gains Exemption (LCGE)

The budget proposes to increase the LCGE on eligible capital gains from $1,016,836 to $1,250,000 for dispositions that occur after June 24, 2024. The indexing of the LCGE to inflation will resume in 2026.

The budget introduces the Canadian Entrepreneurs’ Incentive, which will reduce the taxes on capital gains from the disposition of shares by eligible individuals which meet the following conditions:

• at the time of the sale the share was a share of a small business corporation owned directly by an individual
• used principally in an active business carried on primarily in Canada by the CCPC or a related corporation
• certain shares or debts of connected corporations, or
• a combination of these assets
• the individual was a founding investor and the individual held the share for a period of five years prior to the disposition
• at all times since the share subscription until the time immediately before the sale, the individual directly owned shares with a fair market value (FMV) of more than 10% of the FMV of all of the issued and outstanding shares of the corporation and shares entitling the individual to more than 10% of the votes
• throughout the five year period before the disposition the individual was actively engaged in a regular, continuous and substantial basis in the activities of the business
• the share does not represent a direct or indirect interest in a professional corporation, a corporation whose principal asset is the reputation or skill of one or more employees, or a corporation that carries on certain types of businesses including a business operating in the financial, insurance, real estate, food and accommodation, arts, recreation, or entertainment sector, or providing consulting or personal care services
• the share must have been obtained for fair market value consideration

The incentive would provide a capital gains inclusion rate of one half of the prevailing inclusion rate on up to $2 million in capital gains per individual during their lifetime. The $2 million limit will be phased in over 10 years by increments of $200,000 per year reaching $2 million by January 1, 2034.  

Applying the proposed 2/3 inclusion rate would result in an inclusion rate of 1/3 for qualifying dispositions.  This will apply in addition to the LCGE.

This measure would apply to dispositions that occur after December 31, 2024.

Alternative Minimum Tax (AMT)

The 2023 budget announced amendments to change the calculation of the AMT. Draft legislative proposals were released for consultation in the summer of 2023. (For more information, see our Tax Insights “ Proposed changes to the alternative minimum tax: How will it affect individuals and trusts ”.)

The budget proposes to revise the proposed charitable donation tax credit claim to allow individuals to claim 80% when calculating AMT (as opposed to the previously proposed 50%).

The budget also proposes additional amendments to the AMT proposals including:

• allowing deductions for the Guaranteed Income Supplement, social assistance and workers compensation payments
• fully exempting employee ownership trusts (EOTs) from the AMT, and
• allowing certain disallowed credits under the AMT to be eligible for the AMT carry-forward (i.e. the federal political contribution tax credit, investment tax credits (ITCs), and labour-sponsored funds tax credit)

The amendments would apply to taxation years that begin after December 31, 2023.

The budget also proposes certain technical amendments to the AMT legislative proposals to exempt certain trusts for the benefit of Indigenous groups.

The 2023 budget proposed tax rules to create EOTs. The 2023 Fall Economic Statement proposed to exempt $10 million of capital gains on the sale of a business to an EOT subject to certain conditions.

The budget introduces the conditions for this exemption. The exemption will be available to an individual (other than a trust) on the sale of a business to an EOT where the following conditions are met:

• the individual, a personal trust of which the individual is a beneficiary, or a partnership in which the individual is a member, disposes of shares of a corporation that is not a professional corporation
• the transaction is a qualifying business transfer (as defined in the proposed rules for EOTs) in which the trust acquiring the shares is not already an EOT or a similar trust with employee beneficiaries
• throughout the 24 months immediately prior to the qualifying business transfer, the transferred shares were exclusively owned by the individual claiming the exemption, a related person, or a partnership in which the individual is a member; and over 50% of the FMV of the corporation’s assets were used principally in an active business
• at any time prior to the qualifying business transfer, the individual (or their spouse or common-law partner) has been actively engaged in the qualifying business on a regular and continuous basis for a minimum period of 24 months
• immediately after the qualifying business transfer, at least 90% of the beneficiaries of the EOT are resident in Canada

Where multiple individuals dispose of shares to an EOT as part of a qualifying transfer and meet the conditions above, they may each claim an exemption, however the total exemption in respect of the sale cannot exceed $10 million. The individuals would have to agree on the allocation of the exemption.

If an EOT has a disqualifying event within 36 months of the transfer, the exemption claim will be retroactively denied. If this occurs more than 36 months after a transfer the EOT will be deemed to realize a capital gain equal to the total exempt capital gains. A disqualifying event would result where an EOT loses its status as an EOT or if less than 50% of the FMV of the qualifying business shares is attributable to assets used principally in an active business at the beginning of two consecutive years of the corporation.

The EOT, any corporation owned by the EOT that acquired the transferred shares, and the individual will need to elect to be jointly and severally, or solitarily liable for any tax payable by the individual as a result of an exemption being denied due to a disqualifying event occurring during the first 36 months.  

For the purposes of the AMT calculation the capital gain on the transfer would be subject to an inclusion rate of 30% (consistent with the inclusion rate for capital gains eligible for the LCGE).            

An individual’s normal reassessment period as it relates to this exemption is proposed to be extended by an additional three years.

The budget also proposes to expand qualifying business transfers to include the sale of shares to a workers cooperative corporation, provided it meets certain conditions.

These measures will apply to qualifying dispositions of shares that occur between January 1, 2024 through December 31, 2026.

The budget proposes to double the volunteer firefighters tax credit and the search and rescue volunteers tax credit to $6,000 for the 2024 and subsequent taxation years; this increases the maximum annual tax savings to $900.

The budget proposes to extend the eligibility for this credit for an additional year, so that it will apply to flow-through share agreements entered into before April 1, 2025.

Canada Child Benefit (CCB)

A CCB recipient is no longer eligible to claim the CCB in respect of a child in the month following the child’s death. The budget proposes to extend eligibility for the CCB to six months after the child’s death, provided the individual continued to be eligible for the CCB.

The budget proposes to extend the list of expenses recognized for the disability supports deduction.

It also provides that expenses for service animals, as defined under the medical expense tax credit (METC) rules, will be recognized under the disability supports deduction. The individual will choose whether to claim under the METC or the disability supports deduction.

A foreign charity may register as a qualified donee for a 24-month period where it received a gift from His Majesty in right of Canada and it is pursuing certain activities in the national interest of Canada.  The budget proposes to extend the eligibility of a foreign charity to be considered a qualified donee from 24 months to 36 months.  The foreign charity would also be required to submit an annual information return to the CRA that would be made publicly available. The extension will apply to foreign charities registered after April 16, 2024. The reporting requirements will apply to taxation years beginning after April 16, 2024.        

The budget also proposes to simplify the issuance of official donation receipts by removing certain requirements.

Home Buyers’ Plan (HBP)

To help first-time home buyers, the budget proposes to:

• increase, from $35,000 to $60,000, the amount that an eligible home buyer can withdraw from their Registered Retirement Savings Plan (RRSP) under the HBP, without subjecting the withdrawal to tax, to buy or build a qualifying home (i.e. a first home or a home for a specified disabled individual), effective for the 2024 and subsequent calendar years, for withdrawals made after April 16, 2024
• temporarily extend the repayment grace period by three years, to five years, under the HBP, so that eligible home buyers who withdraw from their RRSP between January 1, 2022 and December 31, 2025 will have up to five years before they need to start repayments to their RRSP

Registered plans (RRSPs, Registered Retirement Income Funds, Tax-Free Savings Accounts, Registered Education Savings Plans, Registered Disability Savings Plans, First Home Savings Accounts, and Deferred Profit Sharing Plans) can invest only in qualified investments for those plans. Qualified investments include mutual funds, publicly traded securities, government and corporate bonds and guaranteed investment certificates. Over the years the qualified investment rules have been expanded to include additional investments for certain plans and to reflect the introduction of new types of plans, but there are inconsistencies and the qualified investment rules are difficult to understand in some cases.

Specific issues are currently under consideration. Stakeholders are invited to submit comments by July 15, 2024 as to how the qualified investment rules can be modernized on a prospective basis to improve the clarity and coherence of the registered plans regime.

Eligible tradespeople and apprentices in the construction industry are currently able to deduct up to $4,000 in eligible travel and relocation expenses per year by claiming the labour mobility deduction for tradespeople. A private member’s bill (Bill C-241) was introduced to enact an alternative deduction for certain travel expenses of tradespeople in the construction industry, with no cap on expenses, retroactive to the 2022 taxation year.

The budget announces that the government will consider bringing forward amendments to the Income Tax Act (ITA) to provide a single, harmonized deduction for tradespeople’s travel that respects the intent of Bill C-241.

The budget proposes to amend the ITA to exclude from taxation the income of the trusts established under the First Nations Child and Family Services, Jordan’s Principle, and Trout Class Settlement Agreement. This will also ensure that payments received by class members as beneficiaries of the trusts will not be included when computing income for federal income tax purposes.

This measure will apply to the 2024 and subsequent taxation years.

Business tax measures

The 2023 budget proposed a refundable ITC for clean electricity, equal to 15% of the capital cost of eligible property. The 2024 budget provides the design and implementation details of the ITC, including the eligibility criteria. It also includes special rules for property that generates electricity from natural gas with carbon capture and property used to transmit electrical energy between provinces or territories, as well as details of the compliance and recovery process.

The ITC will be available only to eligible Canadian corporations, which are defined as:

• taxable Canadian corporations and pension investment corporations
• provincial and territorial Crown corporations (subject to additional requirements)
• corporations owned by municipalities or Indigenous communities

Property eligible for the ITC includes equipment used to generate electricity from:

• solar, wind or water energy (certain class 43.1 property, but hydroelectric installations would not be subject to a capacity limit)
• concentrated solar energy (as defined for the purposes of the proposed clean technology ITC)
• nuclear fission, including heat generating equipment (as defined for the purposes of the proposed clean technology ITC, without the generating capacity limits and other certain requirements of that credit)
• geothermal energy, including heat generating equipment, if it is used exclusively for that purpose (excluding equipment that is part of a system that extracts fossil fuel for sale)
• specified waste materials, as part of a system

Eligible property also includes equipment that is:

• stationary electricity storage equipment and equipment used for pumped hydroelectric energy storage (excluding any that uses a fossil fuel in operation)
• part of an eligible natural gas energy system (special rules apply)
• used for transmission of electricity between provinces and territories (special rules apply)

Previously proposed labour requirements must be met to qualify for the 15% ITC, otherwise a 5% ITC is available. The ITC will be subject to potential repayment obligations, repayable in proportion to the FMV of the particular property when it has been converted to an ineligible use, exported from Canada, or disposed of.

The ITC will be available for new eligible property (i.e. has not been used for any purposes before its acquisition) that is acquired and becomes available for use after April 15, 2024 and before 2035 in respect of projects that did not begin construction before March 28, 2023.

The budget introduces the EV supply chain ITC, equal to 10% of the cost of buildings used in Canada in the following electric vehicle supply chain segments:

• electric vehicle assembly
• electric vehicle battery production
• cathode active material production

To qualify for the ITC, the taxpayer (or member of a group of related taxpayers) must claim the clean technology manufacturing ITC (CTMITC) in all three of the segments (or must claim the CTMITC in two of the three segments and hold at least a qualifying minority interest in an unrelated corporation that claims the CTMITC in the third segment – the building costs of the unrelated corporation would also qualify for the new ITC).

The ITC is effective for property that is acquired and becomes available for use after December 31, 2023. The ITC will be reduced to 5% for 2033 and 2034 and 0% after 2034. Design and implementation details of the ITC will be provided in the 2024 Fall Economic Statement.

The 2023 budget proposed a clean technology manufacturing ITC, and draft legislative proposals were released in December 2023. The 2024 budget proposes to update the clean technology manufacturing ITC for production of qualifying minerals (such as copper, nickel, cobalt, lithium, graphite and rate earth elements) that occur at polymetallic projects (i.e. projects engaged in the production of multiple minerals) by:

• clarifying that the value of qualifying materials will be used as the appropriate output metric when assessing the extent to which property is used (or expected to be used) for qualifying mineral activities producing qualifying materials
• modifying eligible expenditures to include investments in eligible property used in qualifying mineral activities that are expected to produce primarily qualifying materials at mine or well sites, including tailing ponds and mills located at these sites (50% or more of the financial value of the output comes from qualifying materials)

A safe harbour rule will apply to the recapture rule for all qualifying mineral activities, to mitigate against the effects of mineral price volatility on the potential recapture of the ITC, the details of which will be provided at a later date.

Accelerated Capital Cost Allowance (CCA)

Purpose-built rental housing.

The budget provides an accelerated CCA of 10% for new eligible purpose-built rental projects that begin construction after April 15, 2024 and before January 1, 2031, and are available for use before January 1, 2036.

Eligible property will be new purpose-built rental housing that is a residential complex:

• with at least four private apartment units, or 10 private rooms or suites, and
• in which at least 90% of residential units are held for long-term rental

The Accelerated Investment Incentive (AII), which suspends the half-year rule, will continue to apply to eligible property put in use before 2028. The accelerated CCA will not apply to renovations of existing residential complexes, but new additions to an existing structure will be eligible. Projects that convert existing non-residential real estate into a residential complex will be eligible.

Productivity-enhancing assets

The budget provides immediate expensing (i.e. a 100% first-year CCA deduction) for property that is acquired after April 15, 2024 and becomes available for use before January 1, 2027, for the following CCA classes of assets:

• class 44 (patents or rights to use patented information for a limited or unlimited period)
• class 46 (data network infrastructure equipment and related systems software)
• class 50 (general-purpose electronic data-processing equipment and systems software)

The accelerated CCA will be available only for the year in which the property becomes available for use. For a short taxation year, the accelerated CCA must be prorated and will not be available in the following taxation year. Property that becomes available for use after 2026 and before 2028 will continue to benefit from the AII.

Property that has been used (or acquired for use) for any purpose before it is acquired by the taxpayer will be eligible for the accelerated CCA only if both of the following conditions are met:

• neither the taxpayer nor a non-arm’s length person previously owned the property, and
• the property has not been transferred to the taxpayer on a tax-deferred “rollover” basis

The excessive interest and financing expenses limitation (EIFEL) rules restrict a Canadian taxpayer’s deductions for interest and financing expenses, based upon a percentage of its “tax-EBITDA” (i.e. its taxable income, adjusted for items such as interest expenses, depreciation and amortization). For a discussion of the EIFEL rules, see our  Tax Insights “ Bill C-59 ─ Excessive interest and financing expenses limitation (EIFEL) regime .” The EIFEL rules currently include a single sector-specific exemption, for certain interest and financing expenses relating to public-private partnership (P3) infrastructure projects. The budget proposes to extend this election, on an elective basis, for certain interest and financing expenses relating to arm’s length financing that is used to build or acquire certain purpose-built rental housing located in Canada. This exemption will be effective for taxation years beginning after September 30, 2023, consistent with the EIFEL rules more generally. However, this exemption will be available only for expenses incurred before January 1, 2036.

The government is concerned that some landowners are holding residentially zoned vacant land as a speculative investment. The budget announces that the government will consider introducing a new tax on residentially zoned vacant land to spur development. The government will launch consultations later this year.

In March 2024, the government began consultations on how federal policies can better support the needs of all Canadians seeking to become homeowners. The government will provide an update in the 2024 Fall Economic Statement.

The budget announces the government’s intention to restrict the acquisition of existing single-family homes by very large corporate investors. The government will consult in the coming months and provide further details in the 2024 Fall Economic Statement.

The budget announces that the government is exploring new measures to expand access to alternative financing products for home purchasers, such as halal mortgages. These measures could include changes in the tax treatment of these products or a new regulatory regime for financial service providers, while ensuring adequate consumer protections are in place.

The budget proposes several amendments to the CRA’s information gathering provisions in the ITA, with the intent of enhancing the efficiency and effectiveness of tax audits and facilitating the collection of tax revenues on a timelier basis. These changes include:

• allowing the CRA to issue a new type of notice, referred to as a “notice of non-compliance” and to levy a monetary penalty
• permitting the CRA to specify that any required information (oral or written) or documents be provided under oath or affirmation
• imposing a penalty when the CRA obtains a compliance order against a taxpayer, and
• extending the stop the clock rules (which suspend the counting of days in the assessment limitation period), so that these rules apply when a taxpayer seeks judicial review of any requirement or notice issued to the taxpayer by the CRA in relation to the audit and enforcement process, and during any period that a notice of non-compliance is outstanding

Analogous amendments are also proposed to other federal tax statutes administered by the CRA. The budget also proposes certain technical amendments to ensure the rules meet their policy objectives.

These amendments would come into force upon royal assent of the enacting legislation.

The ITA allows a corporation to deduct the amount of any dividends received on a share of a corporation resident in Canada, subject to certain limitations.

One of these limitations is an anti-avoidance rule that denies the dividend received deduction in connection with synthetic equity arrangements. Synthetic equity arrangements include arrangements in which a person receives a dividend on a share, but all or substantially all of the risk of loss and opportunity for gain or profit (the “economic exposure”) in respect of the share are provided to another person.

Where a taxpayer enters into a synthetic equity arrangement in respect of a share, the taxpayer is generally obligated to compensate the other person for the amount of any dividends paid on the share. This compensation payment may result in a tax deduction for the taxpayer in addition to the dividend received deduction. Unless the anti-avoidance rule applies to deny the dividend received deduction, a tax loss would generally arise as a result of the two deductions.

The anti-avoidance rule incorporates certain exceptions, including where the taxpayer establishes that no tax-indifferent investor has all or substantially all of the economic exposure in respect of the share. An associated exception is also available for synthetic equity arrangements traded on a derivatives exchange.

The budget proposes to remove the tax-indifferent investor exception (including the exchange traded exception) to the anti-avoidance rule. This measure would prevent taxpayers from claiming the dividend received deduction for dividends received on a share in respect of which there is a synthetic equity arrangement.

This measure would apply to dividends received after December 31, 2024.

A mutual fund is a type of investment vehicle that allows investors to pool their money and invest in a portfolio of investments without purchasing the investments directly. A mutual fund corporation is a mutual fund organized as a corporation that meets certain conditions set out in the ITA.

The ITA includes special rules for mutual fund corporations that facilitate conduit treatment for investors (shareholders). For example, these rules generally allow capital gains realized by a mutual fund corporation to be treated as capital gains realized by its investors. In addition, a mutual fund corporation is not subject to mark-to-market taxation and can elect capital gains treatment on the disposition of Canadian securities.

To qualify as a mutual fund corporation under the ITA, a corporation must satisfy several conditions, including that it must be a “public corporation”. A corporation can meet this condition if a class of its shares is listed on a designated stock exchange in Canada. A corporation that is controlled by a corporate group may satisfy this condition, and qualify as a mutual fund corporation, even though it is not widely held. The government is concerned that this could allow a corporate group to use a mutual fund corporation to benefit from the special rules available to these corporations in an unintended manner.

Although the government believes this planning can be challenged based on existing rules in the ITA, the budget proposes specific amendments to the ITA to preclude a corporation from qualifying as a mutual fund corporation where it is controlled by or for the benefit of a corporate group (including a corporate group that consists of any combination of corporations, individuals, trusts, and partnerships that do not deal with each other at arm’s length). Exceptions would be provided to ensure that the measure does not adversely affect mutual fund corporations that are widely held pooled investment vehicles.

This measure would apply to taxation years that begin after 2024.

The budget introduces the Canada Carbon Rebate for Small Business, to return a portion of the federal backstop pollution pricing fuel charge proceeds collected from a province. This will be an automatic refundable tax credit for CCPCs with less than 500 employees in Canada in the calendar year in which the fuel charge begins. The tax credit in respect of the 2019-20 to 2023-24 fuel charge years will be available to a CCPC that files a tax return for its 2023 taxation year by July 15, 2024 (with similar timelines for future fuel charge years).

The tax credit amount:

• is determined for each applicable province in which the eligible corporation had employees in the calendar year in which the fuel charge year begins; and
• is equal to the number of persons employed by the eligible corporation in the province in that calendar year multiplied by a payment rate specified by the Minister of Finance for the province for the corresponding fuel charge year

The ITA includes an anti-avoidance rule that is intended to prevent taxpayers from avoiding payment of their tax liabilities by transferring their assets to non-arm’s length persons. The effect of this tax debt avoidance rule is to make the transferee jointly and severally, or solidarily, liable with the transferor for the transferor’s tax debts, to the extent that the value of the property transferred exceeds the amount of consideration given by the transferee for the property.

The ITA contains a number of rules that address various planning techniques employed by taxpayers attempting to circumvent the tax debt avoidance rule, as well as a penalty for those who engage in, participate in, assent to, or acquiesce in planning activity that they know, or would reasonably be expected to know, is tax debt avoidance planning.

The budget includes a new specific measure to address tax debt avoidance planning (although the government believes this planning can also be challenged based on existing rules in the ITA). The measure would apply in the following circumstances:

• there has been a transfer of property from a tax debtor to another person
• as part of the same transaction or series of transactions, there has been a separate transfer of property from a person other than the tax debtor to a transferee that does not deal at arm’s length with the tax debtor, and
• one of the purposes of the transaction or series is to avoid joint and several, or solidary, liability

Where these conditions are met, the property transferred by the tax debtor would be deemed to have been transferred to the transferee for the purposes of the tax debt avoidance rule. This would ensure that the tax debt avoidance rule applies in situations where property has been transferred from a tax debtor to a person and, as part of the same transaction or series, property has been received by a non-arm’s length person. The penalty applicable to those who participate in tax debt avoidance planning would also be extended to this proposed new rule.

In many cases, tax debt avoidance planning is facilitated by a planner who receives a significant fee, which is effectively funded by a portion of the avoided tax debt. The courts have held that a taxpayer who engages in tax debt avoidance planning is normally not jointly and severally, or solidarily, liable for the portion of the tax debt that has effectively been retained by the planner as a fee. The budget proposes that taxpayers who participate in tax debt avoidance planning be jointly and severally, or solidarily, liable for the full amount of the avoided tax debt, including any portion that has effectively been retained by the planner.

Similar amendments would be made to comparable provisions in other federal statutes.

These measures would apply to transactions or series of transactions that occur after April 15, 2024.

The ITA includes a general rule providing that a person who fails to file or make a return or comply with certain specified rules is guilty of an offence, and liable to penalties of up to $25,000 and imprisonment for up to a year. The mandatory disclosure rules in the ITA also include specific penalties that apply in these circumstances, making the application of this general penalty provision unnecessary.

The budget therefore proposes to remove from the scope of the general penalty provision the failure to file an information return in respect of a reportable or notifiable transaction under the mandatory disclosure rules.

This amendment would be deemed to have come into force on June 22, 2023, which is the day the enhanced mandatory disclosure rules received royal assent.

Under the ITA, losses and other tax attributes that arise from expenditures for which a taxpayer did not ultimately bear the cost are generally not recognized. The ITA contains a set of debt forgiveness rules that apply where a commercial debt is settled for less than its principal amount. These rules generally reduce tax attributes by the amount of debt that is forgiven and, where tax attributes have been fully reduced, the rules cause an income inclusion equal to half of the remaining forgiven amount. The ITA also contains a rule that entitles an insolvent corporation to a corresponding deduction to offset all or part of an income inclusion from the debt forgiveness rules.

Bankrupt taxpayers are generally excluded from these debt forgiveness rules. Instead, a separate loss restriction rule applies to extinguish the losses of bankrupt corporations that have received an absolute order of discharge.

The government is concerned that some taxpayers have sought to manipulate the bankrupt status of an insolvent corporation, with a view to benefiting from the exception in the debt forgiveness rules while also avoiding the loss restriction rule applicable to bankrupt corporations. This planning seeks to preserve the losses and other tax attributes of the insolvent corporation (which would otherwise be eliminated upon the forgiveness of its debts), so that these attributes can be acquired and used by a profitable corporation. This planning is the subject of a designated transaction under the notifiable transactions element of the mandatory disclosure rules.

Although the government believes that manipulation of bankrupt status can be challenged based on existing rules in the ITA, the budget proposes a specific legislative measure to address this issue: repealing the exception to the debt forgiveness rules for bankrupt corporations and the loss restriction rule applicable to bankrupt corporations. This change would subject bankrupt corporations to the general rules that apply to other corporations whose commercial debts are forgiven. The bankruptcy exception to the debt forgiveness rules would remain in place for individuals. While bankrupt corporations would be subject to the reduction of their loss carryforward balances and other tax attributes upon debt forgiveness, as insolvent corporations they could qualify for relief from the debt forgiveness income inclusion rule provided under the existing deduction for insolvent corporations.

These proposals would apply to bankruptcy proceedings that are commenced on or after April 16, 2024.

Scientific Research and Experimental Development (SR&ED)

The government launched a consultation on the existing SR&ED tax incentives on January 31, 2024, which closed on April 15, 2024. The budget announces a second phase of consultations, to focus on specific policy parameters, explore how Canadian public companies could become eligible for the enhanced SR&ED ITC and inform how additional funding announced by the budget can support future enhancements to the SR&ED program. Further details of the consultation will be released on the Department of Finance Canada website at a later date.

International tax measures

The Organisation for Economic Co-operation and Development (OECD) has developed a framework for the automatic exchange of tax information relating to transactions in crypto-assets, the Crypto-Asset Reporting Framework (CARF). The budget proposes to implement the CARF in Canada. The new reporting rules will apply to crypto-asset service providers that are resident in Canada, or carry on business in Canada, and that provide services effectuating exchange transactions in crypto-assets. These service providers will need to report certain information regarding their customers and crypto-asset transactions. The budget also includes proposed amendments to the Canadian rules implementing the OECD’s Common Reporting Standard, including changes relating to electronic money products and central bank digital currencies. These measures will apply to 2026 and subsequent calendar years.

A person who makes a payment to a non-resident for services rendered in Canada is currently required to withhold 15% of the payment and remit that amount to the CRA. This is intended to serve as a prepayment of tax that the non-resident may ultimately owe in Canada. Certain non-residents do not owe Canadian tax for these services, e.g. due to exemptions in tax treaties, or exemptions for specific activities like international shipping. In these circumstances, the CRA may provide an advance waiver from the withholding obligation for specific transactions, or the non-residents may apply for refunds of amounts that have already been withheld. The budget proposes to give the CRA legislative authority to grant single waivers that cover multiple transactions occurring over a specific time period, where certain conditions are satisfied. This measure will take effect upon royal assent of the enacting legislation.

The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting has developed a two-pillar plan to reform the international tax system, as part of the “BEPS 2.0” initiative. On October 8, 2021, Canada and 135 other countries in the Inclusive Framework committed to adopt this plan (for a discussion on that commitment, see our  Tax Insights  “ The new international tax framework and Canada’s digital services tax ”). The budget provides an update on the two pillars of this international tax reform initiative.

Pillar One will introduce new rules for allocating taxing rights between countries to address challenges raised by the digital economy. These rules will generally apply to multinational enterprises (MNEs) with annual revenue above €20 billion and profit margins above 10%. The right to tax a portion of these MNEs’ profits will be reallocated to market countries (i.e. the countries where the MNEs’ users and customers are located).

The budget reaffirms Canada’s commitment to bringing Pillar One into effect as soon as a critical mass of countries is willing to participate. In the meantime, Canada is moving ahead with its plan to enact the Digital Services Tax (DST). Implementing legislation for the DST is currently before Parliament in Bill C-59. The DST will take effect beginning in calendar year 2024, with the first year covering taxable revenues earned since January 1, 2022. (For a discussion of the DST, see our  Tax Insights  “ Digital Services Tax: One step closer to becoming a reality .”)

Pillar Two will introduce a 15% global minimum tax. This tax will generally apply to MNEs with global revenues of at least €750 million. These MNEs will be required to compute their effective tax rate (ETR) in each country where they operate. If the ETR for a particular country is below 15%, a top-up tax will be imposed, to raise that ETR to 15% (this top-up tax may be reduced by a substance-based income exclusion, which is computed based on the payroll costs and net book value of tangible assets located in the jurisdiction). Draft legislative proposals for a Global Minimum Tax Act to implement the Pillar Two regime in Canada were released for public comment in August 2023 (for a discussion of those proposals, see our  Tax Insights  “ Canada releases draft Global Minimum Tax Act ”). The budget states that Canada is moving forward with this implementing legislation and intends to introduce it in Parliament soon.

Sales tax measures

Extending goods and services tax (gst) relief to student residences.

On September 14, 2023, the government announced that it would temporarily remove the GST from new purpose-built rental housing projects (i.e. apartment buildings, student housing and senior residences built specifically for long-term rental accommodation) by implementing an Enhanced (100%) GST Rental Rebate for new qualifying purpose-built rental housing projects (for more information, see our  Tax Insights  “ Enhanced GST rental rebate for rental apartments that begin construction after September 13, 2023 ").

To ensure that universities, public colleges and school authorities can also claim the Enhanced (100%) GST Rental Rebate for student residences that are built for short-term use, the budget proposes to amend the  Excise Tax Act  to allow them to apply the normal GST/Harmonized sales tax (HST) rules that apply to other builders (i.e. paying GST/HST on the final value of the building) in respect of new student housing projects.

The budget also proposes to relax the rebate conditions so that universities, public colleges and school authorities that operate on a not-for-profit basis (i.e. those that would currently qualify for the Public Service Body rebates under the GST/HST) can claim the 100% rebate in respect of any new student residence that they acquire or construct provided it is primarily for the purpose of providing a place of residence for their students.

The proposed measures would apply to student residences that begin construction after September 13, 2023 and before 2031, and that complete construction before 2036.

The budget proposes to repeal the temporary zero rating of certain face masks or respirators and certain face shields under the GST/HST for supplies made after April 30, 2024.

Previously Announced Measures

The budget confirms that the government will proceed with the following previously announced measures, as modified to take into account consultations, deliberations and legislative developments since their announcement or release:

• legislative proposals released on December 20, 2023, which include measures relating to the clean hydrogen ITC, the clean technology manufacturing ITC, concessional loans and short-term rentals
• legislative and regulatory proposals announced in the 2023 Fall Economic Statement, which include measures relating to the Canadian journalism labour tax credit, the expansion of eligibility for the clean technology and clean electricity ITC, the GST/HST joint venture election rules and the Underused Housing Tax
• legislative and regulatory amendments to implement the Enhanced (100%) GST Rental Rebate for purpose-built rental housing announced on September 14, 2023
• the carbon capture, utilization and storage and the clean technology ITCs and labour requirements related to certain “clean economy” ITCs
• enhancing the reduced tax rates for zero-emission technology manufacturers
• flow-through shares and the critical mineral exploration tax credit – lithium from brines
• Retirement Compensation Arrangements
• strengthening the Intergenerational Business Transfer framework
• the income tax and GST/HST treatment of credit unions
• a tax on repurchases of equity
• modernizing the General Anti-Avoidance Rule
• global minimum tax and DST
• technical amendments to GST/HST rules for financial institutions
• providing relief in relation to the GST/HST treatment of payment card clearing services
• extending the quarterly duty remittance option to all licensed cannabis producers
• revised Luxury Tax draft regulations to provide greater clarity on the tax treatment of luxury items
• technical tax amendments to the ITA and the Income Tax Regulations
• legislative amendments to implement changes discussed in the transfer pricing consultation paper released on June 6, 2023
• tax measures announced in the 2023 budget, including the dividend received deduction by financial institutions
• substantive CCPCs
• technical amendments to the ITA and Income Tax Regulations
• legislative amendments to implement the hybrid mismatch arrangements rules announced in the 2021 budget

The budget also reaffirms the government’s commitment to move forward, as required, with technical amendments to improve the certainty and integrity of the tax system.

Integration – Capital gains ($)

(taxation year ended December 31, 2024, and $10,000 of capital gains earned after June 24, 2024)

This table shows:

• the income tax deferral (prepayment) if capital gains in excess of $250,000 are earned and retained in a corporation as opposed to being earned directly by an individual
• the tax (cost) if the after-tax corporate income is paid out as a dividend to the shareholder in 2024

The table assumes:

• the individual is in the top marginal tax rate
• no capital gains deductions are available
• the non-taxable portion of the capital gain is distributed as a tax-free capital dividend
• the taxable dividend paid is sufficient to generate a full refund of refundable tax 

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Tax Insights: 2024 Federal budget ─ Supporting housing, raising taxes

Dean Landry

National Tax Leader, PwC Canada

Tel: +1 416 815 5090

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