Integration of corporate and personal income taxes

In Canada, corporate income is subject to corporate income tax and, on distribution as dividends to individuals, personal income tax. The personal income tax system, through the gross-up and dividend tax credit (DTC) mechanisms, currently provides recognition for corporate taxes, based on a 20 per cent notional federal-provincial rate, to taxable individuals resident in Canada.

Because of tax policy issues relating to the proliferation of publicly traded income trusts, the federal government has proposed to introduce an enhanced gross-up and DTC for eligible dividends received by eligible shareholders. An eligible dividend will be grossed-up by 45 per cent, meaning that the shareholder includes 145 per cent of the dividend amount in income. The DTC in respect of eligible dividends will be 19 per cent, based on the expected federal corporate tax rate in 2010. The existing gross-up and tax credit will continue to apply to other dividends. Eligible dividends will generally include dividends paid after 2005 by public corporations (and other corporations that are not Canadian-controlled private corporations) that are resident in Canada and subject to the general corporate income tax rate.