The Department of Finance has further indicated that associated CCPCs would not be required to share the maximum subsidy of $25,000 per employer. Additionally, since the subsidy operates by allowing an eligible employer to reduce their payroll remittances, the Department of Finance suggested that if the amount of the subsidy exceeded an eligible employer’s payroll remittances for the applicable period, the employer would be allowed to continue to reduce remittances beyond June 20, 2020, or request the unclaimed amount be paid out to the eligible employer or credited against the eligible employer’s 2021 payroll remittances.

Further tax commentary on the 10% wage subsidy can be found here^[14].

75% wage subsidy (“CEWS”)

Tax commentary on the CEWS can be found here^[15], here^[16] and here^[17], including commentary on the administrative guidance^[18] issued by the CRA in respect of the CEWS on April 21, 2020.

Proposed Relief for Registered Pension Plans

To provide relief to employers who sponsor registered pension plans or salary deferred leave plans, the Department of Finance released draft regulations^[19] on July 2, 2020, which:

• Add temporary stop-the-clock rules to the conditions applicable to salary deferral leave plans from March 15, 2020 – April 30, 2021;
• Remove restrictions that prohibit a registered pension plan from borrowing money;
• Permit retroactive contributions to a money purchase account to replace contributions that were not made in 2020, and to ensure that retroactive contributions plus regular contributions in 2021 do not exceed the maximum contribution limit (the pension adjustment limit) for 2021.;
• Setting aside the 36-month employment condition in the definition “eligible period of reduced pay” for the purpose of using prescribed compensation to determine benefit or contribution levels. As well, the requirement that the reduction in pay must be generally commensurate with the reduction in work hours.

The announcement did not specify when the draft regulations would come into effect.