LEGISLATION
FEDERAL BUDGET BILL INTRODUCED
Bill C-15, Budget 2025 Implementation Act, No. 1, was introduced on November 18, 2025. It includes amendments to the Income Tax Act (ITA), Income Tax Regulations (ITR) and Excise Tax Act (ETA) to implement some (but not all) measures announced in the Federal Budget 2025, as well as some previously announced measures. Explanatory Notes for Bill C-15 are also available. These measures include:
- ITA and ITR amendments to facilitate the handling of unclaimed property of unlocated members; these amendments generally follow the earlier proposed amendments, and will apply to amounts paid or transferred to an unclaimed property authority after December 31, 2026 (one year later than originally proposed)
- Bare trusts (i.e., trusts that act as agent for their beneficiaries with respect to all dealings in trust property) will no longer have to file an annual trust return or be subject to the beneficial ownership reporting requirements in section 204.2 of the ITR (beneficiary disclosure in Schedule 15 to the T3 return); this amendment applies for taxation years ending after December 30, 2024
- The beneficial ownership reporting requirements will also no longer apply to retirement compensation arrangements that supplement retirement benefits (supplemental pension plans) or to employee ownership trusts; these amendments will apply to taxation years ending after December 30, 2025
- ITA amendments to allow a tax-deferred transfer of the commuted value of an annuity acquired in satisfaction of a member’s entitlement to benefits under an RPP, if the pension benefit is divided because of marriage breakdown or pension legislation permits the annuitant to commute or surrender the annuity (if the original annuity purchase is with respect to a DB provision, the DB transfer limits will apply to the indirect transfer from the annuity to other registered vehicles); this amendment is deemed to have come into force on January 1, 2018
- Various amendments to the tax-free savings account and first home savings account provisions of the ITA and ITR, with different effective dates
Other 2025 Budget announcements not included in Bill C-15 include:
- Simplifying and consolidating the qualified investment rules applicable to registered plans under the ITA
- Funding the Business Development Bank of Canada to launch a new fund-of-funds to leverage more private venture capital from pension funds and other institutional investors
- Offering a voluntary Early Retirement Incentive program under the Public Service Pension Plan so that eligible employees (with a minimum age of 50 or 55 depending on Group, and at least 10 years of employment and two years of pensionable service) can retire with an immediate pension based on years of service
- Consulting on CPP and QPP enhancements so that federal employees will continue to receive the same pension benefits but will contribute less