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Force travel

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This article details a subject that falls under the Legends brand.

Force travel was a Force power which allowed a being to travel great distances instantly by creating a momentary rift in space. This power caused the user to be corrupted by the dark side , as it broke the normal rules of the galaxy by ripping the Force asunder. The technique became more corrupting to use depending both on how far away the target was, as well as how familiar the Force-user was with the location.

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American Forces Travel

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American Forces Travel℠     is the only official joint services MWR leisure travel website.

American Forces Travel is a joint service initiative combining the efforts of each of the five branches of service (Army, Marine Corps, Navy, Air Force and Coast Guard) and the Office of the Deputy Assistant Secretary of Defense for Military Community & Family Policy. Who is Eligible:  Active military, Guard or Reserve, U.S. Coast Guard, Retired Military, and all eligible MWR patrons.

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What is American Forces Travel?

American Forces Travel (AFT) is a new site launched with Priceline that offers discounted travel prices to military service members and their dependents. Despite there being many unofficial sites that boast discounted travel prices for military, AFT is the ONLY official joint service owned leisure travel service for the military community.

Priceline.com a company with over 20 years of online travel expertise, won out the opportunity to sponsor AFT over other travel discount sites in a competitive bidding process AFT was launched as an initiative by five military branches of service and the Office of the Secretary of Defense to provide a modernized, streamlined method for booking travel and vacation packages for the military community.  Previously, most non-official travel for military had been orchestrated through base tickets and tour offices; AFT provides a platform where military members can search for special travel deals online.

What Sets American Forces Travel Apart From Other Discount Sites?

  • AFT boasts up to 60% savings on more than a million hotel deals in more than 76,000 destinations worldwide.
  • AFT offers reduced fees for reservation changes and all flights cancellable within 24 hours.  With AFT, there is also free cancellation on post-paid cars as well as cancellation discounts for pre-paid rates.
  • AFT offers 24/7 customer support.
  • There is a commission that goes towards military Morale, Welfare, and Recreation services and military quality of life programs with each transaction on the AFT site.
  • Although Priceline.com offers similar discounts and deals for the general public, Priceline has a special team dedicated to the AFT site to search for the best prices specifically for military members.
  • Priceline offers the same lowest price guarantee on AFT as it does on its main site.  If a better price or deal is found for any travel arrangements within 24 hours of booking, Priceline will refund 100% of the price difference.

Who is Eligible to Use American Forces Travel?

  • Active duty and dependents
  • Full-benefit retirees and dependents
  • 100% disabled veterans and dependents
  • Medal of Honor recipients and dependents
  • American Red Cross and USA-paid personnel serving outside of the US and dependents
  • DOD civilians and non-appropriated fund employees

How Do I Sign Up To Use American Forces Travel?

- Visit the American Forces Travel site .

- Select the “Get Started” link from the main page.

- You will be prompted to verify your military status by providing your last name, date of birth, and the last four digits of your social security number.

- This information does not go through Priceline but is verified against a DOD database.

- Login information is not captured or retained in any way.

What Types of Discounts Does American Forces Travel Offer?

  • Travel packages

AFT hopes to also offer discounts on theme parks and other attractions at a future date

Does American Forces Travel Really Deliver Discounts to the Military Community?

A review done by Military.com of the American Forces Travel site uncovered that on travel to San Diego, hotel deals ranging $20-$50 dollars less than prices found on regular travel discount sites and $10-$18 off per day for vehicle rentals.  According to the same review, a round-trip Alaska Airlines flight from Washington, D.C. to San Diego for one February weekend was $354, while on American Forces Travel the same round-trip flight was only $323.  However, non-stop flights for the same weekend could be purchased on United Airlines for $200-$400 less on a travel discount site other than AFT.

Discounts on hotels seems to vary by season and by room type. For example, a cursory search on AFT for hotels in Seattle, WA during the month of August showed variance in discounted prices when compared to prices on other discount travel sites, ranging from prices on AFT being $10-$20 higher than to $10-$30 lower than on other travel sites. It did seem that there were better discounts on searches for double occupancy rooms than on searches for rooms for more than two people, which could signify that when looking for hotels, AFT offers better discounts for groups travelling with less people as opposed to families with children or larger groups.

Discounts on automobile rentals also vary by auto type and rental by day or by week. Cruise prices also appear to vary based on season or berthing type.

In short, there is probably still no substitute for doing the research when one is looking for good deals on travel. AFT probably does offer significant discounts for military members but not necessarily on every travel item nor in every circumstance, so it is still important to search for deals and discounts using various resources. 

It’s important to consider, too, that AFT launched only within the past few months and still has plans to expand its scope and improve its services. It would be well worth providing further analysis after the site has been up and running for a year or two. 

At the very least American Forces Travel puts another discount travel booking tool in the back pockets of military members and their dependents and can be considered a legitimate means to secure the best price for all leisure travel needs.

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American Forces Travel℠ is a new Morale, Welfare and Recreation (MWR) program arising out of a joint service initiative combining the efforts of each of the five branches of service (Army, Marine Corps, Navy, Air Force and Coast Guard) and the Office of the Deputy Assistant Secretary of Defense for Military Community & Family Policy.

Because the Internet is now the most popular way to research and book travel, the branches of Service chose to evolve their travel offering. The Services have contracted with a world leader in travel, Priceline®, to deliver high value travel benefits to the U.S. military community. American Forces Travel℠ is transforming the way MWR provides online leisure services to our Service members and families, empowering them to revitalize, reconnect, be well, and most importantly, be mission-ready. In addition to dramatically enhancing quality of life for the military community, American Forces Travel℠ will inject critical revenue into MWR programs by providing commissions from every booking made.

Awarding the no-cost contract to Priceline® is a major milestone for the Services and a testament to their collaborative and transformative efforts. While there are many for-profit online leisure travel offerings marketing to the military today, American Forces Travel is the only official joint services MWR leisure travel website.

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American Forces Travel – Online Travel Discounts

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American Forces Travel

Update: As of July 16, 2021, all current and former military members* are eligible to use American Forces Travel. *Veterans must have a discharge status of honorable or general under honorable conditions to be eligible for AFT.

American Forces Travel (AFT) is a leisure travel booking website sponsored by the Department of Defense and intended for servicemembers and veterans across all military branches. Through American Forces Travel, eligible users are able to find steeply discounted rates on airfare, cruises, hotels, rental cars, vacation packages, and event tickets (concert, sporting, theatre).

Launched in 2019, AFT is a Morale, Welfare, and Recreation (MWR) program that enables servicemembers and veterans to easily search for and view leisure travel discounts and benefits exclusively available to military members, those affiliated with the Department of Defense, and eligible family members.

Why Should I Try American Forces Travel?

Convenience.

American Forces Travel offers an attractive and convenient alternative to in-person MWR facilities and Information Tickets & Travel (ITT) offices located on military installations because it can be reached 24/7 online and offers around-the-clock military traveler support. Additionally, AFT has broader eligibility criteria than in-person MWR sites; therefore, some groups who may not be eligible to benefit from MWR services on-site may be eligible to avail themselves of AFT instead.

Helps to Fund Other MWR Programs

Booking through American Forces Travel also helps to fund other MWR programs, since commissions from each booking are reinvested at no cost to users.

Lower Booking Fees

American Forces Travel has lower booking fees than other commercial travel websites and offers a “best price guarantee.” For cruises, they even offer a 110% best price guarantee , meaning that if you find a cheaper cruise within 48-hours of booking with American Forces Travel, they will refund 110% of the difference.

Exclusive Offers and Military Rates

Unlike other discount travel sites, American Forces Travel has exclusive offers and military rates, which means less time spent calling airlines and hotels inquiring about military offers.

Greater Global Reach

Users can book domestic and international travel to over 71,000 locations courtesy of American Forces Travel.

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How Does It Work?

The American Forces Travel website is extremely user-friendly, owed largely in part to its partner — Priceline . Priceline.com has been a long-time leader in online travel services — which acts as the service provider. However, not all of the deals offered commercially through Priceline are identical to those on AFT, since Priceline has a specific team in place to negotiate additional deals for military members and affiliates.

In order to book leisure travel through the online platform, users will first have to verify their eligibility, which requires some personal information (last name, birth date, and the last four digits of the user’s Social Security number).

The website will search the DEERS database in order to verify eligibility, so be sure to keep your information in DEERS up to date prior to using the AFT page. After eligibility is established, you’re free to access AFT to search for discounted travel and leisure options.

Am I Eligible to Use American Forces Travel?

Currently, AFT is available to military servicemembers and those affiliated with the Department of Defense, including:

  • Active duty servicemembers (Army, Navy, Air Force, Marine Corps, Coast Guard, Space Force, and Coast Guard Auxiliary Active Duty)
  • Members of Reserve components and National Guard
  • Retired military (including retirement-eligible Reservists and Guardsmen)
  • Medal of Honor and Purple Heart recipients ; former prisoners of war
  • Veterans with service-connected disabilities
  • Department of Defense civilians serving outside the United States
  • Active duty and retired U.S. Public Health Service and National Oceanic and Atmospheric Administration employees
  • Full-time, paid employees of the American Red Cross and United Service Organizations (USO) serving at overseas U.S. DoD installations
  • Officially sponsored, eligible family members ( ID card holders)
  • Approved primary family caregivers of eligible veterans
  • All Veterans of the United States Armed Forces with a discharge status of honorable or general under honorable conditions.

However, eligibility criteria are expanding and AFT will soon (specific dates still unknown) be available to all Department of Defense civilians serving within the United States as well as all Coast Guard and Department of Homeland Security (DHS) civilians registered in DEERS.

American Forces Travel should not be confused with Armed Forces Vacation Club , another discount travel option for military members and veterans. AFVC offers discounted hotel and resort stays.

About Post Author

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Meaghan Doherty Myers

Meaghan Doherty Myers is a freelance writer, specializing in military benefits, personal finance, and defense and security issues. She holds an M.A. in Strategic Studies and International Relations from the Johns Hopkins School of Advanced International Studies (SAIS) and recently graduated from the Russian language program at the Defense Language Institute in Monterey, CA. She is an Army spouse, a former ballet dancer, and a former management consultant who lives with her husband and daughter in Alexandria, VA.

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7 Things to Know About the American Forces Travel Booking Site

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Many or all of the products featured here are from our partners who compensate us. This influences which products we write about and where and how the product appears on a page. However, this does not influence our evaluations. Our opinions are our own. Here is a list of our partners and here's how we make money .

Service members, veterans and their families now have a one-stop shop for finding and booking travel with military discounts. The Department of Defense has teamed up with Priceline to create a travel booking site exclusively for U.S. military members.

It only takes a quick eligibility check on the American Forces Travel booking site to begin accessing savings that claim to include up to 60% off hotel stays.

Here are seven questions about the new site, answered.

1. What kinds of travel can be booked through the site?

Eligible members of the military and Department of Defense can book everything from flights and rental cars to vacation homes and hotels. Even cruises are available on the site.

The site, which is powered by Priceline, can be used for booking domestic and international travel, and boasts hotel deals in more than 71,000 destinations around the globe.

American Forces Travel also offers packages that users can use to book flights in combination with hotels or car rental for even deeper discounts. On Priceline’s site, travelers who book a package save $240 per transaction per person, on average. People will see similar savings on American Forces Travel.

In the future, American Forces Travel hopes to also offer discounts on theme parks and other attractions.

» Learn more: Beat your travel budget and find cheap activities in any city

2. Who is eligible?

American Forces Travel is open to all military and military-affiliated personnel who are eligible to use Morale, Welfare and Recreation programs. That's an estimated 9 million people.

The list of people who are eligible to use American Forces Travel includes:

Active-duty members and their families.

Full-benefit retirees and their families.

Veterans who are100% disabled and their families.

Medal of Honor recipients and their families.

American Red Cross and USA paid personnel who are serving outside of the United States and their families.

Department of Defense civilians.

Veterans and non-active members who did not retire with full benefits should be eligible later in 2019. The Department of Defense has said it intends to make them eligible but has not specified a date yet.

3. How do I find out if I’m eligible?

The eligibility check is on the American Forces Travel site. Users will enter their last name, the last four digits of their Social Security number and their date of birth. Then the information is checked against the Department of Defense’s records.

Priceline is not part of the verification process and does not capture or retain that data.

4. What kind of savings can military members expect?

American Forces Travel will offer hotel deals up to 60% off and cruise deals up to 80% off. Military members will have access to discounts on 1.2 million hotels, as well as deals on flights and car rentals.

» Learn more: Credit card offers for active-duty military

5. Are these discounts different than what nonmilitary travelers might find on Priceline?

Some of the discounts are different because Priceline has a team dedicated to negotiating additional deals for American Forces Travel.

6. Outside of travel deals, what else can American Forces Travel provide?

The same services exist for American Forces Travel that exist for Priceline customers, including 24-hour customer service and insurance options for all forms of travel.

7. Why was American Forces Travel created?

Previously, military families would have booked travel with a travel agent on a military base. The Department of Defense created American Forces Travel to make the process faster, more modern and accessible.

In addition, travel booked through American Forces Travel will generate a commission that will support Quality of Life programs for each branch of the military.

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Planning a trip? Check out these articles for more inspiration and advice: Nerdwallet’s top travel credit cards Thank you for your service: Military student loan rights Credit card offers for active duty military personnel

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Introducing American Forces Travel: Department of Defense and Priceline Unveil Deeply Discounted Leisure Travel Site Exclusive to US Military Community

January 22, 2019

American Forces Travel to Feature a Worldwide Assortment of Extraordinary Deals on Flights, Hotels, Vacation Homes, Rental Cars, Cruises and Packages

The United States Department of Defense today officially introduced American Forces Travel ( www.americanforcestravel.com ), a new leisure travel site it created with Priceline. American Forces Travel was developed for current and retired members of the U.S. military and their families, along with DoD civilians. It is a unique and unprecedented travel service: a global collection of exceptional deals, assembled in a single place and available only to the United States military community. American Forces Travel was developed to ensure that when authorized members book personal travel, they will have ready access to the best deals that the global travel industry has to offer.

American Forces Travel is a full-service travel booking platform. It features the world’s most popular hotel, flight, car rental and cruise brands. More than a million hotel deals will be available in more than 71,000 destinations around the globe. The site will also offer privately negotiated deals on flights and rental cars, as well as vacation homes, apartments, cruises, vacation packages and more. American Forces Travel deals are accessible because of the site’s exclusivity to the military community and are only available to those who are serving, or have retired from service, in the United States military.

The Department of Defense (DoD) ranks among the world’s largest employers, with some 1.3 million people in active service around the world. Until now, leisure travel was typically handled by travel agents on military bases. The DoD chose to create a new online platform that was modern, fast and widely accessible, and to populate the site with the broadest and deepest collection of travel deals as a way to thank the military community for their service.

Priceline was selected at the end of a competitive bidding process among many of the largest online travel agencies. Priceline’s enduring relationships with travel brands the world over, its experience in negotiating special deals with those partners, and the company’s twenty years of online travel expertise promise to make this offering successful for all. This site is the result of a joint service initiative among the five branches of America’s armed forces – the Army, Marine Corps, Navy, Air Force and Coast Guard – along with the Office of the Secretary of Defense.

“American Forces Travel was developed for a simple reason. The people who support the United States of America through military service have earned access to the world’s most exclusive travel deals,” said Brett Keller, Priceline’s CEO. “We were thrilled to be selected by the Department of Defense, and have worked closely with them over the past year to bring the site to life.”

American Forces Travel will also feature “package” or “bundled” booking options – a way for users to save even more when they travel. A bundled booking combines private rates that are typically only accessible in a package. The savings can run into the hundreds of dollars, which would not be available if a traveler booked each travel element independently.

All transactions on American Forces Travel will generate a commission that will support Quality of Life programs within each service branch.

Eligibility Verification

Today, American Forces Travel is open to all military and military affiliated personnel who are eligible to use Morale, Welfare and Recreation programs. First-time users will be asked to verify their eligibility with the Department of Defense. Once verified, they are free to use the site to book discounted travel around the world. The verification process is secure and requested information will not be retained.

About Priceline

Priceline, part of Booking Holdings Inc. [NASDAQ: BKNG], is a leader in online travel deals. Priceline offers travelers smart, easy ways to save on hotel, airline, rental car reservations, packages and cruises. With access to more than a million lodging properties of all type, consumers can find the right accommodations, as well as free cancellations and the option to pay upon arrival. Priceline’s Express Deals® offer exclusive savings without bidding, and our Name Your Own Price® service delivers the lowest hotel prices available on Priceline.com. With Priceline, travelers can save at every stage, freeing them up to travel more and travel better.

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American Forces Travel Privileges Extended to Eligible Veterans

The Department of Defense announced today a policy change to the current shopping privileges on the American Forces Travel website. As directed by acting Under Secretary of Defense for Personnel and Readiness Virginia S. Penrod in a memo signed April 12, 2021, the department will extend online access to the website to honorably discharged veterans of the uniformed services.

On average, customers save 35-40% compared to commercial travel pricing by using AFT. This includes discounted rates on hotels (up to 60%), airfare, rental cars, vacation packages, event tickets, and cruises.

“Sixteen million veterans will now be able to access the American Forces Travel website, joining the 10 million active duty, Guard and reserve service members, family members, DOD civilians, and other patrons who are already receiving the benefit,” said Deputy Assistant Secretary of Defense for Military Community and Family Policy Patricia “Patty” Montes Barron. “We are committed to providing quality-of-life programs to our military community, which includes our honorably discharged veterans.”

The change will not affect access for existing patrons, and the increased customer base will allow AFT to negotiate better prices for its customers. 

AFT launched in 2019 as the only official joint service morale, welfare, and recreation leisure travel website exclusively for DOD patrons. In addition to improving access to DOD’s MWR benefits, every booking on American Forces Travel generates revenue to support critical quality-of-life programs for service members and families.

To access the exclusive military discount pricing on travel products, visit the American Forces Travel website . Proof of eligibility is required.

About Military Community and Family Policy

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25 characters powerful enough to take down the phoenix.

The Phoenix Force is beyond powerful, but which Marvel Comics characters can defeat the X-Men cosmic entity?

The Phoenix is one of the most powerful cosmic beings in Marvel Comics, able to destroy stars and generate destructive power on a scale that's hard to imagine. The X-Men barely survived their initial and classic encounter with the entity in "The Dark Phoenix Saga," leading to the question of who else in Marvel Comics would be able to defeat the Phoenix.

Many powerful beings and forces exist within the Marvel Universe, some of which are beginning to emerge in the MCU. The Scarlet Witch's exploration of chaos magic could potentially lead to a confrontation between chaos magic and the Phoenix Force. It's one that's already happened in the comics, with shocking results for readers. But there are plenty of heroes who can go toe-to-toe with Jean Greye's Phoenix Force, and who have proved it in the comics already.

"The Dark Phoenix Saga" storyline spans Uncanny X-Men #129-138

25 Kang The Conqueror

Kang found the biggest loophole to taking on the phoenix force: time travel.

In an actual fight where he is left to his own devices, Kang the Conqueror does not stand a chance against the Phoenix Force and he isn't likely to make for a suitable host either. However, Kang has one loophole that other suitors on this list don't: he has the power of time travel on his side . He has mastered all of the reality bending implications of time travel.

If Kang ever finds himself in a scenario where he must combat the Phoenix Force, he doesn't have to risk his life in an unwinnable bout against a cosmic entity. Instead, he can travel back in time to kill its host before said host acquires the Phoenix Force , or even prevent the host from being born altogether. Not even a cosmic being is immune to the complexities the timestream.

24 Echo (AKA Maya Lopez)

Echo has proven she can handle the strongest version of the phoenix.

Echo is one of the more recent hosts to the Phoenix Force and may rank as the most unexpected hosts as well. However, when she acquired the Phoenix Force, it was believed that she could even more powerful than Jean Grey , In due time, this would prove to be the case as she received the biggest upgrade in the history of Phoenix lore . There were concerns from Echo herself that she could become as dangerous to others as Scarlet Witch once was , but she manages to grasp control of the Phoenix Force.

It's clear that Echo harnesses an untapped potential as a hero, considering that she's able to handle the strongest version of the Phoenix. Anyone strong enough to control a force that powerful without being overtaken by the Dark Phoenix is powerful enough to defeat it.

23 Legion (AKA David Haller)

Even a being like the phoenix is unlikely to be able to handle legion's power.

David Haller, or Legion, is the unstable, yet all-power Omega Level son of Professor Xavier. He suffers from dissociative identity disorder brought apart largely from his mind struggling to contain his level of power. As a result, many of his powers manifest themselves as entirely new personas for David. Some may wonder how someone who can hardly control his own powers could possibly stand a chance against the Phoenix. That's exactly what gives him an edge in a hypothetical fight with the Phoenix.

X-Men: The 6 Most Powerful 'Beyond Omega Level' Mutants, Ranked

In a worst case scenario where the Phoenix tries to overwhelm David as its host, Legion is one of the more likely candidates who would have it under control. If David can hardly contain himself, surely the Phoenix wouldn't be able to , and thus David (or one of his personalities) would be the one overwhelming the Phoenix. Plus, in an actual fight with the Phoenix Force, David has reality bending powers on his side that should make things easier.

22 The Stepford Cuckoos (AKA Emma's Clones)

The clones of emma frost could achieve what the qhite queeb couldn't, alone.

There was once a time when Emma Frost absorbed the powers of the Phoenix, but it proved too powerful for her to handle, morphing her into the Dark Phoenix. That considered, it's unlikely that Emma could take on the Phoenix herself on her own accord, despite how powerful she is, but three heads of Emma Frost are better than one .

The trio of Emma Frost clones are typically relegated to the background of X stories as supporting characters at best, but they get a well deserved spotlight in X-Men: Phoenix - Warsong, where the sisters find themselves locked in the crosshairs of the Phoenix. Miraculously, when the Phoenix overwhelms the rest of them, it is Celeste who manages to overpower the beast. One Emma Frost may not be enough to handle the Phoenix, but the clones are the trio that Marvel needs in timely distress such as this.

21 Fongji Wu (AKA The Immortal Iron Fist)

The wielder of the iron fist could tame the phoenix.

Hundreds of years before Danny Rand or even Lin Lie would adopt the Iron Fist, the moniker belonged to Fongji Wu. Brian Michael Bendis' New Avengers #26 and #27 depicts her origin story, from training to handle the Iron Fist to preparing to tackle the incoming Phoenix Force.

To everyone's surprise, Fongji Wu is able to face down the Phoenix Force and absorb it whilst remaining in full control , becoming the firebird's new host. If she can handle the power of the Phoenix Force, she most certainly has a chance to defeat it. Wu may be one of the more obscure people to ever wield the power of the Phoenix Force, but she might also be one of the most powerful knowing she was able to endure the Phoenix Force, presumably for the rest of her life.

20 The Goblin Force

The cosmic force that is equal to, if not stronger, than the famous phoenix force.

There are not many cosmic entities out there that have the capacity to match the Phoenix Force in power. The Goblin Force comes the closest. The Goblin Force hails from an alternate reality where it was spawned at the beginning of time itself alongside the Big Bang. It carries striking similarities to the Phoenix Force, including holding unlimited power, except the Goblin Force feeds off hunger, not satisfied until its appetite its whet. One has to wondered if its hunger can ever be satisfied considering the depths it has gone to feed itself.

The Goblin Force not only killed The Phoenix Force, but Galactus as well . It could not be defeated or destroyed itself, thus the need for the Celestials to imprison it as a last-ditch effort to contain it. The Goblin Force already proved itself worthy in a fight against the Phoenix Force.

19 The Hunger

The cosmic entity ruled by hunger can swallow the phoenix force whole.

The Hunger is more than just a cosmic entity - it's a multiversal parasite that feeds on entire realities and universes. Much like The Goblin Force itself, The Hunger (unsurprisingly, considering the name) is driven by feeding its appetite, an appetite that's extremely difficult to satisfy. It's also far more sentient than either the Phoenix Force or the Goblin Force, so when it is in an aggressively hungry mood, it has no problem letting it be known to anyone listening. When it can devour entire realities, the Phoenix doesn't stand a chance.

Earth-616 was not on The Hunger's radar until it learned about the Infinity Gauntlet, putting him in conflict with Thanos. It wound up devouring several cosmic beings in the distant future and even destroying Thanos. It took a time-traveling, omnipotent Thanos to finally defeat The Hunger.

18 Moon Knight (AKA Marc Spector)

The fist of khonshu is powerful enough to reject the phoenix force.

Moon Knight actually served as the host of the Phoenix Force for a brief time. But when he realized just how devastating the entity actually was, Moon Knight did something unthinkable: he rejected the Phoenix Force on purpose . While caught up in a fight with the Avengers, Moon Knight allows Thor to knock him out, forcing the Phoenix Force to move on and find a new host.

It's hard to find someone capable of the sheer willpower it takes to resist the influence of the powerful force. But Marc Spector managed to do it, giving the hero a surprising advantage over the cosmic power.

17 Galactus (AKA The Devourer of Worlds)

The cosmic villain has already taken the phoenix to the limit.

The Devourer of Worlds has actually fought against the Phoenix, in Excalibur #61 from 1993. This was the Rachel Summers version of the character, arguably at the height of her powers. Galactus was at the ebb of his, hungry and weak.

Phoenix was able to defeat him in a truly cosmic battle, but if Galactus had been at full strength, the circumstances would have been very different in this titanic battle .

16 Molecule Man (AKA Owen Reece)

Molecule man's cosmic abilities make the phoenix force seem like an amateur.

As powerful as the Beyonder, Molecule Man has not only saved the entire Marvel universe but also recreated it, proving that he's more powerful than the Phoenix .

If the Watcher has his eye on you, you know you're a dangerous threat to the multiverse. Previously, Molecule Man's powers had been strong but not omnipotent, which later changed as his limitations were lifted over the years. Considering that, after Secret Wars , Molecule Man serves as a hidden architect of the cosmos, he could definitely take on the Phoenix.

15 Nebula (With The Infinity Gauntlet)

The harnessed power of the infinity stones is enough to challenge the phoenix.

For a brief moment in The Infinity Gauntlet comic book series in the early 90s, Nebula wielded the power of the Infinity Stones in her hands. The combined power of the stones is truly cosmic and given what has been accomplished with them, presents a major challenge to the Phoenix.

On a pure power level, the Gauntlet and the Phoenix stack up . The difference is willpower, and at least in the comics, Nebula was very driven to get her hands on the Gauntlet. Though her time with it was brief, she proved to be very dangerous with its awesome power.

14 Spider-Man (AKA Peter Parker)

Spider-man has already proven capable of defeating multiple phoenix hosts (at once).

The Amazing Spider-Man managed to defeat not one, but two hosts of the Phoenix Force at once . In Avengers vs. X-Men #9 , Peter is forced to confront Colossus and Magik, two members of the Phoenix Five. Spider-Man stands no chance against the powerful siblings and is at a serious disadvantage. However, he tricks Magik and Colossus into attacking one another, knocking them both out and keeping himself alive.

Peter is used to fighting above his weight class, and it seems that even a power like the Phoenix Force isn't too much for Spider-Man to handle as long as he can think on his feet.

13 Thor (AKA The Odinson)

The god of thunder managed to knockout the phoenix with the might of mjolnir.

Thor is one of the most powerful Avengers in the comics and the MCU, but even with all his might, the God Of Thunder alone can't defeat the Phoenix Force. But he has proven that he can best the cosmic entity with the power of Mjolnir, his mystical hammer.

In a battle between King Thor, a future version of the Son of Odin, and the Phoenix Force, Thor knocks the powerful entity out with the hammer . This isn't enough to destroy it, but it suggests that he has the power at least to go toe to toe with it. Also, it was recently revealed that, shortly after his birth, Thor was imbued with the power of the Phoenix , and he could even command its fire for a while.

12 Doctor Strange (AKA Stephen Strange)

Thanks to his mastery of magic, this isn't even a fair fight for the phoenix.

The Sorcerer Supreme is one of the most powerful magicians in the Marvel Universe, if not the most powerful. Doctor Strange has proven his power in the MCU, able to trap the interdimensional entity of Dormammu in a time loop and also perceive infinite variations of time to give the Avengers an advantage.

In many respects, the comic book version of Doctor Strange is even more powerful. With near-complete authority over the mystical arts, he has a power the Phoenix simply doesn't have . He could theoretically exorcise the Phoenix from its host, which would change the parameters of the fight dramatically.

11 Iron Man (AKA Tony Stark)

The phoenix buster is just what's needed to defeat the cosmic entity.

While Tony Stark was never able to completely beat the Phoenix Force, he certainly was able to stop the powerful creature when he, along with the Avengers, went up against the Phoenix and the X-Men in the Avengers Vs. X-Men crossover event. As he usually does, Tony Stark built a special armor for the occasion: the Phoenix Buster.

The Phoenix Buster is one of Iron Man's most powerful armors. It worked, and the Phoenix Force was broken up into different segments . These segments took on hosts of their own, eventually becoming the Phoenix Five, but Tony Stark was able to beat it temporarily.

10 Doctor Doom (AKA Victor Von Doom)

Just like every other being, doctor doom has beaten the phoenix in canon already.

While Doom's victory against the Phoenix Force isn't conventional, it's a strong indication of what would happen if he faced it in a normal circumstance.

Victor Von Doom is capable of many things, and yes, he's even canonically beaten the Phoneix Force before . In Secret Wars #4 , a number of heroes attempted to stop the villain from reshaping reality to his will, including Cyclops, who was channeling the Phoenix Force. However, Doom was possessing the power of Molecule Man and the Beyonders, making him too much for the mutant to handle.

Doom is up for any challenge and isn't afraid to fight any being, regardless of their power. While Doom's victory against the Phoenix Force isn't conventional, it's a strong indication of what would happen if he faced it in a normal circumstance.

9 Death (AKA Lady Death)

The phoenix can use its force to defeat almost any enemy... but not even it can escape death.

The literal personification of Death in Marvel Comics was at the epicenter of Thanos' iconic Infinity Gauntlet snap in the comics. She has power in her own right and her status as a fundamental force of the cosmos makes her effectively unassailable to the Phoenix Force .

Death possesses unlimited intelligence and power and operates from a pocket reality that is all her own. In a direct fight, it's unlikely the Phoenix would be able to defeat Death in any way.

8 Beyonder (Name Unknown)

The beyonder operates well outside of the phoenix's force.

The Beyonder comes from a race of nearly-omnipotent beings who reside outside the Marvel Universe, in the remnants of the Second Cosmos. He was the villain of the iconic original Secret Wars and its less-than-successful sequel, and his brethren were the culprit behind the destruction of the Multiverse that culminated in 2015's Secret Wars .

As the Beyonders once destroyed the entire Multiverse, that also included cosmic personifications such as the Living Tribunal and (even if it wasn't shown) the Phoenix Force. While the Phoenix is perhaps the most powerful cosmic force, it's still constrained by the laws of the Multiverse, while the Beyonder operates outside of them .

7 Thanos (With The Infinity Gauntlet)

The gauntlet's most iconic wielder can unleash its full power.

Comic fans know Thanos is an Eternal of Titan, making him extremely powerful and essentially immortal. This isn't enough to put him in the league with the Phoenix Force, though. With the power of the Infinity Gauntlet, he at least has a shot.

He displayed not only its power but his evil nature when he snapped away half of all life in the universe. This was an act far beyond even the Phoenix's most destructive moments and sets up the possibility that Thanos could defeat the Phoenix with a snap of his fingers.

6 Odin (AKA The Allfather)

As the former lover of the phoenix, nobody knows her weaknesses better.

Odin was the All-Father of Asgard, wielder of the might of the gods, of ancient and forgotten magic, and of his own cosmic power, called the Odinforce. With such a powerful arsenal at his disposal, it's not unlikely to think that Odin could beat the Phoenix Force, under the right circumstances.

He also shares a strange connection with the Phoenix Force, revealed in the Thor Generations comic. The Odin from the Avengers 10,000 B.C. storyline actually had a romantic relationship with the Phoenix Force , perhaps giving him some insight into its weaknesses.

Trans care restrictions force some families to travel hours, spend hundreds for treatment

More than 20 states have gender-affirming care restrictions.

Misty Stamm was working tirelessly to figure out the details: waking up early, the hourslong drives, booking hotels and finding doctors who could legally administer gender-affirming hormone therapy to her 16-year-old transgender daughter.

Stamm is living in one of the 24 states where legislation is restricting gender-affirming health care for transgender youth, so she and parents like her must make long, expensive trips out of their home states to find the care their children need, according to a new report from the Campaign for Southern Equality Research and Policy Center.

“If we didn't have the care, I don't think she'd be alive,” said Stamm.

Stamm, who lives in Tennessee, drove five hours to get her daughter to a gender clinic in Ohio when her family first started considering care options. She wanted her daughter to be seen by a physician in person.

With new gender-affirming care restrictions set to go into effect soon in Ohio, Stamm and her daughter have since turned to a telehealth provider in Virginia.

However, they still have to drive two hours to Virginia for the online appointment, as to not break Tennessee law, which also bans telehealth providers from providing care and treatments like puberty blockers and hormone therapies to a minor located in the state.

Stamm told ABC News that the time, effort and money they’re spending to access care is worth it.

When she came out as transgender at 13, “the mental health issues stopped completely,” said Stamm. “That affirmed to us that this was the right thing.”

Stamm's daughter had been in counseling and therapy since she was in fifth grade, struggling with her mental health and experiencing depression, anxiety and suicidal ideations.

PHOTO: In this Feb. 26, 2024, file photo, a woman and her daughter wave Pride flags from the East Balcony of the Tennessee House during debate of HB 1605, banning pride flags in Tennessee Public Schools, at the Tennessee State Capitol in Nashville, Tenn.

At age 14, Stamm's daughter received puberty blockers to temporarily pause the development of physical sex characteristics. As her daughter grew older, the family and physicians together decided to move forward with hormone therapy. Throughout this process, they said, psychologists and therapists were consulted and were required for approvals.

“There's no talk of surgery or anything like that,” said Stamm. “That's a decision that she can make when she is an adult.”

Meanwhile, her mental health has progressed exponentially – Stamm said her daughter has since been released by her therapist and is only seen occasionally, as needed.

"She's just doing so well, and if we didn't have access -- we have to have it. She has to have it."

MORE: Report: LGBTQ content drove book banning efforts in 2023

Gas, airfare, lodging and other expenses to cross state lines and access gender-affirming care could cost hundreds to thousands of dollars, the Southern Equality report states.

Stamm says she and her husband have spent likely thousands of dollars in travel costs to get care and are anxiously awaiting the day their daughter turns 18 so she can access care more freely.

The report from Southern Equality Research and Policy Center found that it could take almost 20 hours of driving roundtrip for some families across the South and Midwest to reach a state where trans youth care is legally accessible.

Families with transgender children across southern Florida, Louisiana, Missouri and Texas are the hardest hit, according to the report -- they would need to take a more than eight-hour car ride one way to get to a clinic that serves trans youth.

For Jennifer, an Austin, Texas, resident who asked to go by a pseudonym for safety concerns, said the health care bans in her state threw her family into logistical and financial chaos.

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Her 15-year-old daughter’s appointments to begin hormone therapy were canceled before the law in Texas even went into effect. When they sought out care in Louisiana, providers also were canceling appointments.

She sought out the help of local advocacy groups to help her family find a provider in Texas' neighbor to the west, New Mexico.

However, the costs continue to mount: “We are in a position that we could afford to buy plane tickets and stay in a hotel for a couple of nights and pay all of the out-of-pocket expenses for the medical care,” said Jennifer. “For a lot of people, that's probably not an option.”

Though telehealth has expanded opportunities for access to care, policies like those in Tennessee restrict these appointments for prescriptions from happening in the state and force some families like the Stamms to cross borders for online appointments.

PHOTO: Tennessee Gov. Bill Lee appears at an event on Feb. 29, 2024, in Nashville, Tenn.

Tennessee Gov. Bill Lee, who signed the gender-affirming care ban , has defended the bill against legal challenges.

"Tennessee is committed to protecting children from permanent, life-altering decisions," said Lee in a post on social platform X after the Justice Department argued the law violates the Fourteenth Amendment's Equal Protection Clause.

Supporters of gender-affirming medical care bans argue that children should wait until they’re older to make these medical decisions, and that there needs to be more research on the impact of these procedures on patients.

In the state’s court filings in opposition to a lawsuit against the ban, the state invokes Dobbs v. Jackson Women’s Health Organization – the decision which overturned Roe v. Wade and ended federal protections for abortion rights.

The state argues that Dobbs allows states “to regulate medical treatments” and that it does not discriminate against transgender people because “not all transgender individuals use puberty blockers, hormones, or surgery.”

“This Court should acknowledge divergent views and hold that the responsibility to choose between them rests with the people acting through their elected representatives,” read the state’s filing.

The Tennessee Legislature is now considering a bill that could make it a felony to help a minor access gender-affirming care out-of-state without parental consent.

MORE: Kansas governor vetoes gender-affirming trans youth care ban

PHOTO: In this Aug. 30, 2023, file photo, students protest against Katy ISD's new transgender policy outside the school district's educational support complex, in Katy, Texas.

Transgender care for people under 18 has been a source of contention for state politicians in recent years, impacting a group estimated to make up less than 1.5% of the population ages 13-17, according to an estimate from researchers at the University of California, Los Angeles .

Often due to discrimination, stigma, and gender-related stress, trans youth are at increased risk for poor mental health and suicide, substance use, experiencing violence, and other health risks, according to the Centers for Disease Control and Prevention.

Major national medical associations, including the American Academy of Pediatrics, the American Medical Association, the American Academy of Child and Adolescent Psychiatry, and more than 20 others have argued that gender-affirming care is safe, effective and medically necessary.

“Allowing them to live in their identity is what saves their mental health,” Jennifer said in response to criticism over transgender medical care.

As families continue to seek out avenues for care, Jennifer and Stamm want lawmakers to know that they're just a "normal, regular family."

“I want them to see us as people,” Jennifer said. “We are their neighbors, we are people who teach their kids in school. We are people they work with.”

Stamm adds, "She's just a regular kid, just trying to be a regular kid. … This has just presented so many challenges for her and we feel isolated. Our circle is tight and small ... Hopefully, people will be a little bit more empathetic to what we're going through. And how ridiculous all of this is."

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Heathrow Border Force strike: Officers to walk out for four days as union protests against job cuts

More than 300 workers will walk out between 29 April and 2 May.

Tuesday 16 April 2024 22:02, UK

Hundreds of Border Force officers will go on strike at Heathrow Airport later this month.

They will walk out for four days over changes to their working conditions, according to the Public and Commercial Services trade union.

The union said more than 300 of its members working at terminals 2, 3, 4 and 5 of the airport will walk out from 29 April to 2 May.

Around 250 of them will lose their jobs at passport control under new roster plans, the union says.

PCS general secretary Fran Heathcote said: "Our members are angry and disappointed at being forced out of their jobs.

"While not everyone will be affected, the changes will disproportionately hit those who are disabled or have caring responsibilities.

"The Home Office should be doing all it can to retain experienced, trained staff - not lose them by introducing an unworkable new roster system."

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Strikes planned for last week were suspended amid hopes of talks to resolve the row, but the union has now reinstated industrial action.

The Home Office said it was "disappointed" with the union's decision but added it remains "open to discussing a resolution".

It added: "The changes we are implementing will bring the working arrangements for Border Force Heathrow staff in line with the way staff work at other ports, provide them with more certainty on working patterns, and improve the service to the travelling public.

"Keeping our borders secure remains our top priority and we have robust plans in place to minimise any potential disruption."

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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

Dean Landry

National Tax Leader, PwC Canada

Tel: +1 416 815 5090

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