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EAMG Market Commentary July 2024
Rates & Credit – In Q2 2024, U.S. inflation and economic growth data was mixed, leading to moderately higher interest rates in the U.S. Meanwhile, in Canada, long-end interest rates were little changed during the quarter, but short-term interest rates fell. That was due to the weaker economic outlook, as well as the Bank of Canada’s decision to reduce its overnight interest rate in June, with anticipation of further monetary policy easing to come. Canadian corporate bonds returned 1.1%, outperforming the 0.8% return of government bonds as well as the 0.9% return for the overall FTSE Canada Universe Bond index. Shorter-dated bonds outperformed longer-dated bonds. Within corporate bonds, lower-rated BBBs outperformed higher-rated A bonds, while industries that have shorter-dated debt (e.g. real estate and financials) outperformed those that tend to have longer-dated debt (e.g. communications and infrastructure).

Equity Overview – Against the backdrop of volatile inflation data and a lack of indication from the Federal Reserve that it was prepared to start cutting interest rates yet, U.S. equity markets decoupled from other regions. Crowding into AI-focused, mega-cap names accelerated in Q2. More specifically, investors defaulted toward the Magnificent 7 to navigate the current period, overlooking broadening earnings breadth and less expensive valuations from the remaining S&P 493. Outside the U.S., equity returns were generally mundane in dollar terms. That said, emerging markets proved to be a bright spot for investors seeking value, as the rebound in heavily discounted Chinese equities helped push frontier markets higher.

U.S. Fundamentals – Corporate earnings continued to surpass expectations last quarter with stable operating margins helping businesses report better-than-expected bottom line results. Investors remain focused on the ability of companies to sustain debt levels ahead of renewing debt obligations, rewarding businesses with a strong ability to generate stable cash flows. Moreover, while prior quarters have witnessed earnings growth that was largely driven by highly profitable mega-cap technology stocks, U.S. markets are witnessing a broadening trend in earnings strength, with previously stunted segments of the market recovering. Our work shows that members of the Russell 1000 index, excluding the Magnificent 7, posted a median earnings growth of about 6% last quarter, with nearly 60% of companies increasing earnings versus the year prior. Furthermore, we observed an increase in the number of major companies that expect improving financial performance to approximately 27%, suggesting that the recovery in earnings breadth may persist.

U.S. Quant Factors – As mentioned, concentration in the equity market drove a surge in valuations as investors continued to chase specific mega-cap technology stocks. In fact, within the Russell 1000 growth factor – which screens for companies whose earnings are expected to grow at an above-average rate relative to the market – the Magnificent 7 totaled nearly 55% of the entire index by quarter-end. In addition, the Nasdaq 100 – which is generally viewed as a technology-biased index – saw the weight of the Magnificent 7 rise to almost 43% of the entire index by the end of the quarter. Furthermore, the equal-weighted S&P 500 underperformed the cap-weighted index by nearly 7% last quarter, bringing the year-to-date divergence to about 10%. With concentration accelerating, the cap-weighted index outperformance has soared past Covid-era levels, a period that saw investors rapidly crowd into profitable technology names due to panic and economic uncertainty. We remain cautious of a severely crowded market that trades near all-time highs as strong performance from 5-7 names distorts the overall stature of market conditions.

Canadian Fundamentals – Although Canadian companies exceeded bleak forecasts, earnings continue to contract on a year-over-year basis. Furthermore, earnings revisions have grinded lower with easing monetary conditions unable to offset concerns of a slowing economic environment. We note the sharp contrast versus the U.S. as the bifurcation of earnings performance widens. The CRB Raw Industrials Index, a measure of price changes of basic commodities, broke out of recent ranges as metals rallied higher despite a stronger U.S. dollar and elevated interest rates. The mining industry benefited from a sustained elevation in prices, helping the materials sector outperform over the quarter. Returns from the heavily-weighted Canadian banks were constrained last quarter with company-specific drivers – including regulatory challenges from TD, and underwhelming U.S. results from BMO – limiting performance. More broadly, the banks continue to build prudent credit provisions to mitigate uncertain economic forecasts and remain well capitalized.

Canadian Quant Factors – With investors remaining attentive to businesses’ ability to create value relative to financing costs, we see value in high quality, dividend-paying companies with strong earnings sustainability and a healthy degree of leverage. Based on our work, investors of the Canadian banks appear well compensated, with the current premium between value creation and current yield remaining compressed. In our opinion, the market has modest expectations regarding prospects for value generation from the banks and, therefore, we believe the industry stands to benefit if the premium reverts closer to historical norms. We also continue to see sources of quality dividend opportunities within certain areas of the energy sector. More specifically, we believe companies that have taken steps to improve their balance sheets through deleveraging efforts, and with improved operating leverage, offer attractive prospects given their stable and high-yielding composition.

Views From the Frontline

Rates – During the first half of the second quarter, interest rates in both Canada and the U.S. increased, continuing the upward momentum from Q1. Higher-than-expected inflation data in the U.S. along with mixed economic growth data caused investors to push out expectations for when the U.S. Federal Reserve would start lowering its interest rate. This trend shifted in the second half of Q2, as positive economic momentum slowed in the U.S. economy and inflation data began to soften. Interest rates in Canada declined more rapidly than in the U.S. due to more benign inflation, a weaker job market, and economic growth remaining below population growth. This economic weakening provided the confidence required for the Bank of Canada to cut rates by 25 basis points in June to 4.75%. The Bank also signaled that if inflation continues to ease and the Bank’s confidence grows that inflation would continue to trend toward its 2% inflation target, it is reasonable to expect further cuts. The second quarter marked a pivotal point for the global policy easing cycle. Sweden, Canada, and the European Central Bank all began lowering their policy rates, and Switzerland made a second rate cut, following one in Q1. The market continues to speculate on the timing of the U.S. Federal Reserve’s first rate cut. Interest rate cut expectations are largely unchanged in Canada since last quarter, with a total of three rate cuts expected throughout 2024. Expectations for the rate cuts by the U.S. Federal Reserve declined slightly, however, to two cuts in 2024.

Credit – The risk premium for corporate bonds (versus government bonds) was largely flat over the quarter, with spreads approaching the tight post-pandemic levels experienced in 2021. Corporate bond supply continues to be very robust, with $41bn in new issuance. Year-to-date, corporate issuance has set a new record, with an impressive $80bn in issuance. On balance, we do not think the current risk premium adequately compensates for downside risk, particularly in longer-dated corporate bonds, and have a bias towards shorter-dated credit where we view the risk / reward trade-off as being more favourable.

Equity – On the backdrop of a heavily concentrated U.S. market rally, we remain cautious of the distortion to market returns from high-flying technology stocks. As a result, we continue to favour a combination of the Dow Jones Industrial Average and the S&P 500 for our broad U.S. market exposure. The Dow provides a more diversified exposure to 30 prominent large-cap companies and less concentration in technology relative to the S&P. Broadening earnings strength presents an opportunity for previously out-of-favour names to “catch-up”. In our view, companies outside the Magnificent 7 that have demonstrated robust earnings growth, strong cash flow generation, along with decreased debt loads, are well-positioned to benefit from internal market rotations. As such, we gain exposure to these companies through the quality factor – companies with higher return-on-equity, strong operating performance, and healthy leverage levels – and the dividend growth factor – businesses with a lengthy and established history of increasing dividends.

In Canada, we remain attentive to how efficiently corporations are generating profits relative to financing costs. Looking forward, we continue to monitor the ability of businesses to generate profits given a decline in capital spending. More specifically, we are focused on businesses’ ability to grow and sustain dividends amid the lag between easing monetary conditions and consumption. Due to this, we observe value in higher yielding companies that are higher on the spectrum of quality. Geographically, we maintain our overweight U.S. exposure, underpinned by encouraging U.S. inflation data trends, broadening corporate earnings growth, and normalizing consumption. In addition, sluggish Chinese data and the lack of positive earnings revisions from EAFE tilt the risk-adjusted return profile in favour of the U.S. Lastly, as a Canadian investor, fluctuations in the Loonie’s relative value versus other major currencies continues to present tactical trading opportunities within our investment mandate.

Downloadable Copy

Mark Warywoda, CFA VP, Public Portfolio Management	Ian Whiteside, CFA, MBA AVP, Public Portfolio Management	Johanna Shaw, CFA Director, Portfolio Management	Jin Li Director, Equity Portfolio Management
Tyler Farrow, CFA Senior Analyst, Equity	Andrew Vermeer Senior Analyst, Credit	Elizabeth Ayodele Analyst, Credit	Francie Chen Analyst, Rates

ADVISOR USE ONLY

Any statements contained herein that are not based on historical fact are forward-looking statements. Any forward-looking statements represent the portfolio manager’s best judgment as of the present date as to what may occur in the future. However, forward-looking statements are subject to many risks, uncertainties, and assumptions, and are based on the portfolio manager’s present opinions and views. For this reason, the actual outcome of the events or results predicted may differ materially from what is expressed. Furthermore, the portfolio manager’s views, opinions or assumptions may subsequently change based on previously unknown information, or for other reasons. Equitable^® assumes no obligation to update any forward-looking information contained herein. The reader is cautioned to consider these and other factors carefully and not to place undue reliance on forward-looking statements. Investments may increase or decrease in value and are invested at the risk of the investor. Investment values change frequently, and past performance does not guarantee future results. Professional advice should be sought before an investor embarks on any investment strategy.

Market Comments - October 2024

Key Takeaways for Q3

· Central banks eased monetary policy by reducing their target interest rates.
· Bond markets performed very well during the quarter as interest rates fell.
· Risk markets experienced some volatility, but stock markets had robust returns.
· Canadian stocks outperformed U.S. stocks in Q3, while the sources of returns in the U.S. market were more balanced and diversified than in the first half of the year.

Views From the Frontline

Bond Markets: During the third quarter, interest rates in both Canada and the U.S. moved significantly lower as markets anticipated that the Bank of Canada would continue – and the Federal Reserve would start – cutting rates. Additionally, the expectation became that the central banks would end up lowering rates more aggressively than previously assumed. That’s because inflation data has softened sufficiently to give the central banks the scope to ease policy, and other economic data, especially from the labour market, indicated the need for them to ease policy in order to prevent economic activity from cooling too much. For instance, in Canada, inflation slowed to the Bank of Canada’s 2% target, while the labour market showed warning signs with the unemployment rate rising to 6.6%. The Bank of Canada cut its target interest rate by 0.25% at each of its July and September meetings. Governor Macklem indicated that if growth does not materialize as expected, “it could be appropriate to move faster on interest rates”. In the U.S., the Federal Reserve kicked off its easing cycle by cutting its target rate by 0.50% in September. The growing signs of a cooling labour market amidst slowing inflation motivated the larger-than-typical move. That said, consumer spending in the U.S. continued to be strong, and GDP is still tracking a healthy growth rate.

While interest rates fell, bonds returns were also boosted by solid behaviour of corporate bonds. Credit spreads (i.e. the risk premium for corporate bonds versus government bonds) continued to grind lower over the quarter. Tightening credit spreads reflected the generally positive risk-on tone to the market, despite some volatility. Lower-rated BBB bonds performed better than higher-quality A-rated bonds. Credit spreads have now generally fallen back to levels that are largely consistent with the tight post-pandemic levels experienced in 2021. The on-going appetite of investors for the extra yield offered by corporate bonds over government bonds is indicated not just by falling credit spreads, but also by investors’ enthusiasm to support the primary issuance market. Corporate bond supply continues to be very robust, with $29B (billion) in new issuance during the quarter, resulting in an impressive $119B issued year-to-date, a new record. Nonetheless, on balance, we do not think the current risk premium adequately compensates for downside risk, particularly in longer-dated corporate bonds, and have a bias towards shorter-dated credit where we view the risk / reward trade-off as being more favourable.

Stock Markets: In the U.S., we continue to caution against heavily concentrated sources of market returns and emphasize a diversified portfolio. Last quarter, diversification proved essential as a multitude of factors heightened market volatility. These factors – which included the unwind of the yen carry trade, investor reactions to mixed mega-cap earnings, and concerns of a slowing labour market – drove investors away from mega-cap technology names and into defensive areas of the market. Following the Federal Reserve’s decision to reduce interest rates by 0.5%, sources of investment returns continued to broaden as investors rotated into economically-sensitive baskets. Underpinned by decelerating inflation and easing monetary policy, we believe the rotation away from the mega-cap tech names is likely to persist and we continue to emphasize portfolio diversification. In Canada, high-quality, high-yielding businesses – composed of the financial sector and non-financial dividend payers – outperformed over the quarter as investors rewarded companies that demonstrated a strong ability to sustain dividends, as well as greater efficiency generating profits. While we continue to favour these businesses, we have taken profit on our financial sector dividend exposure after a sharp reversion in the premium between value creation and current yield. In addition, Chinese officials introduced a wave of stimulus to revitalize growth, bringing life back to the metals and luxury goods sectors. Accordingly, Canadian and European equities have benefitted recently.

Market Update

Rates & Credit: In Q3, interest rates in both Canada and the U.S. decreased significantly, with front-end interest rates declining faster than long-end interest rates amid cooling inflation and a weakening labour market. As a result, the FTSE Canada Universe Index posted a positive return of 4.7%. Coincidentally, Canadian corporate bonds and government bonds each also generated returns of 4.7%, totally in-line with the Universe index. On the other hand, despite short-term interest rates falling much more than long-term interest rates, the higher price sensitivity of long-dated bonds had them outperform shorter-dated bonds, with the Long-Term bond index up 5.8% while the Short-Term bond index gained 3.4%. Similarly, within corporate bonds, industries that have longer-dated debt (e.g. energy and infrastructure) outperformed those that tend to have shorter-dated debt (e.g. real estate and financials).

Equity Overview: Underpinned by decelerating inflation data and easing monetary policy – including the outsize 50-basis cut from the Federal Reserve – prospects for an economic soft landing increased over the quarter. That favourable outlook spurred global equity markets to all-time highs, with previously lagging areas of the market narrowing the performance gap compared to the U.S. mega-cap technology names that had led returns in the first half of the year. Canadian equities outperformed their U.S. counterpart last quarter, rising 10.5% as strength in the banking and materials sectors pushed the index higher. Major developed markets from Europe, Australasia, and the Far East (EAFE) were more subdued, gaining 0.9% (in local currency terms) last quarter. That said, grand expectations for further interest rate cuts in the U.S. pushed the greenback to its lowest level in over a year, boosting EAFE returns to over 7% in U.S. dollar terms. Within the U.S., sources of market returns broadened as well, with investors rotating out of concentrated AI companies and into more economically sensitive businesses.

U.S. Fundamentals: Outside of the Magnificent 7, investors are interpreting downside earnings surprises as a normalization of financial performance rather than a deterioration. For example, McDonald’s share price rallied over 17% into quarter-end following its earnings release despite announcing declining sales and contracting earnings per share. Within the AI-ecosystem, investors are beginning to look for opportunities beyond chip manufacturers, such as nuclear energy providers. At an index level, our work shows that members of the Russell 1000 index, excluding the Mag-7, posted a median earnings growth of nearly 9% year-over-year, expanding from the ~6% witnessed in Q2. Furthermore, the number of companies from this group reporting positive earnings growth grew to approximately 67%, up from 60% in the prior quarter. In our view, the ongoing broadening of earnings strength outside of the Mag-7 can provide tailwinds to current market rotations into previously left-behind companies. Within the mega-cap tech space, investors have become more discriminant than in prior quarters, rewarding businesses with greater success monetizing their AI-investments. This trend was evident through the divergence of returns from IBM and Alphabet (Google’s parent company) following their quarterly earnings.

U.S. Quant Factors: Decelerating U.S. inflation data prompted a rotation out of highly concentrated areas of the market (growth) and into more economically-sensitive companies (value). Then, concerns of a slowing U.S. labour market and the unwind of the yen carry trade increased market volatility, leading investors to shelter their positions by reallocating to low volatility. As the quarter progressed, expectations of easing monetary policy and stabilizing employment data helped calm return to the market and the rotation from mega-cap tech sector resumed, albeit at a lesser pace. Notably, this “catch-up” trade also benefitted dividend-paying companies, particularly those with a lengthy and established history of increasing dividends, as investors favoured those more mature operations.

Canadian Fundamentals: Investors returned to the Canadian market after Canadian companies showed signs of recovery last quarter with earnings expanding by more than expected. With inflation showing clearer signs of deceleration and the outlook regarding the path of monetary policy increasingly implying lower interest rates going forward, investors are allocating toward high-quality, dividend-paying companies. From a sector level, surging gold prices provided a tailwind for Canadian miners, helping the materials sector outperform over the quarter. More recently, the materials sector has benefitted from elevated base metal prices following the arrival of Chinese stimulus. In contrast, oil prices declined over 16% last quarter as fears of an oversupplied market swelled following speculation that OPEC+ would look to dial back production cuts. As a result, investors looked past lingering geopolitical risks and the energy sector underperformed.

Canadian Quant Factors: Amid an improving Canadian macroeconomic backdrop and clearer outlook on the trajectory of monetary policy, dividend-yielding businesses became sought after. More specifically, investors continued to emphasize dividend sustainability last quarter, rewarding dividend-paying businesses that demonstrated strong financial performance and the ability to support future payouts. For example, the major Canadian banks sharply outperformed in Q3 after reporting earnings growth that mostly exceeded expectations. In essence, investors have become more constructive on this high-yielding group as their ability to create value relative to financing costs improves.

Downloadable Copy

Mark Warywoda, CFA VP, Public Portfolio Management	Ian Whiteside, CFA, MBA AVP, Public Portfolio Management	Johanna Shaw, CFA Director, Portfolio Management	Jin Li Director, Equity Portfolio Management
Tyler Farrow, CFA Senior Analyst, Equity	Andrew Vermeer Senior Analyst, Credit	Elizabeth Ayodele Analyst, Credit	Francie Chen Analyst, Rates

ADVISOR USE ONLY

Any statements contained herein that are not based on historical fact are forward-looking statements. Any forward-looking statements represent the portfolio manager’s best judgment as of the present date as to what may occur in the future. However, forward-looking statements are subject to many risks, uncertainties, and assumptions, and are based on the portfolio manager’s present opinions and views. For this reason, the actual outcome of the events or results predicted may differ materially from what is expressed. Furthermore, the portfolio manager’s views, opinions or assumptions may subsequently change based on previously unknown information, or for other reasons. Equitable® assumes no obligation to update any forward-looking information contained herein. The reader is cautioned to consider these and other factors carefully and not to place undue reliance on forward-looking statements. Investments may increase or decrease in value and are invested at the risk of the investor. Investment values change frequently, and past performance does not guarantee future results. Professional advice should be sought before an investor embarks on any investment strategy.

[pdf] Segregated Fund Annual Report - December 31, 2024
[pdf] Advisors Edge Insurance for Children Article
All about the changes to the capital gains inclusion rate Disclaimer: The following content is provided by and is the opinion of Invesco Canada Ltd. Equitable does not guarantee the adequacy, accuracy, timeliness, or completeness of the information. Equitable shall not be liable for any errors or omissions in the information provided by Invesco.

What has changed?
One noteworthy measure to come from Budget 2024 is the proposed change to the capital gains inclusion rate, which was previously held steady at 50% since 2001.

For individuals, capital gains more than $250,000 annually will be subject to an increased 66.67% inclusion rate as of June 25, 2024, while the capital gains up to $250,000 will continue to be subject to the existing 50% inclusion rate. As a transitional measure for 2024, only the capital gains realized by individuals on or after the effective date of June 25 that are above the $250,000 threshold will be subject to the increased inclusion rate.

For trusts and corporations, the inclusion rate on all capital gains will increase from 50% to 66.67% starting on June 25, 2024.

Who is affected?

Impact to individuals
Budget 2024 proposed to add transitional rules which would specifically identify capital gains and losses realized before the effective date (Period 1) and those realized on or after the effective date (Period 2). The effective date is June 25, 2024. Capital gains realized on or after that date will have an inclusion rate of 50% on the amount up to $250,000, and an inclusion rate of 66.67% on the amount above $250,000. All capital gains realized prior to the effective date will have an inclusion rate of 50%.
Take Ontario as an example, the proposed higher inclusion rate on capital gains would effectively increase the average federal-provincial marginal tax rate for Ontario residents on capital gains above $250,000 at the top marginal tax rate from 26.76% to 35.69%. A more detailed analysis on the impact of these changes to an individual’s tax rate is discussed below.
For net capital gains realized in Period 2, the annual $250,000 threshold would be fully available in 2024 (i.e., it would not be prorated) and it would apply only in respect of net capital gains realized in Period 2.
The $250,000 threshold would effectively apply to capital gains realized by an individual, either directly or indirectly via a partnership or trust, net of any: 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, the proposed employee Ownership Trust Exemption or the proposed Canadian Entrepreneurs’ Incentive claimed.
Two common scenarios of reaching the $250,000 capital gain threshold are the deemed disposition of capital property at death, and the emigration from Canada (i.e., becoming a non-resident for income tax purposes). We have provided additional details on these topics below.

Deemed disposition upon death
When an individual passes away, they are deemed to have sold their capital property (e.g., units or shares of mutual funds, shares of corporations, and real property) at its fair market value (FMV) immediately before their death. If a capital gain arises because of this deemed disposition, that capital gain is reportable on the deceased’s final (terminal) tax return and the taxes owing as a result, if any, would be payable by the estate of the deceased. However, there are provisions that allow taxes to be deferred when the property is transferred to a spouse. For example, if a capital property is transferred to a surviving spouse or common-law partner, subsection 70(6) of the Income Tax Act (Canada) automatically deems the deceased to have disposed of that property and the spouse or common-law partner immediately acquires the same property at the deceased transferor’s adjusted cost base (ACB). This is commonly referred to as the “spousal rollover”. Another potential strategy to manage potential large capital gains taxes at death is life insurance, since the death benefit is typically paid out tax-free.
Without careful planning, the estate value could be substantially reduced by the changes to the capital gains inclusion rate. Furthermore, it would be prudent to ensure there are liquid assets or cash available in the estate to cover the associated tax liabilities.

Non-resident of Canada – Departure tax
Residency in Canada for income tax purposes is a question of fact, which primarily depends on the individual’s residential and social ties in Canada. When an individual becomes a non-resident of Canada, they are deemed to have disposed of and immediately reacquired certain types of property at FMV. The tax incurred because of this deemed disposition and reacquisition is also known as the departure tax. Some examples of properties subject to departure tax include securities inside a non-registered investment portfolio, shares of Canadian private corporations, and real estate situated outside of Canada. Note that there are some properties that are exempted from the departure tax, including: pensions and similar rights (including registered retirement savings plans (RRSPs), registered retirement income funds (RRIFs), and tax-free savings accounts (TFSAs)) and Canadian real property.
The departure tax rules coupled with the increased capital gain inclusion rate above the $250,000 threshold may incur additional tax payable for emigrants. However, there is an option to defer the payment of departure tax on income associated with the deemed disposition upon emigration. By making an election, the individual would pay the tax later, without interest, when the property is disposed of. This election can be done by completing CRA Form T1244, “Election Under Subsection 220(4.5) of the Income Tax Act, to Defer the Payment of Tax on Income Relating to the Deemed Disposition of Property," on or before April 30 of the year following their departure from Canada.

Impact to Entities
Corporations and trusts will also be impacted by the increased inclusion rate as of June 25, 2024. Unlike individuals, corporations and trusts will not have access to the old inclusion rate on the first $250,000 of capital gains: they will be subject to the new 66.67% inclusion rate from the very first dollar.
With the above in mind, there will be options available to shelter corporate and trust capital gains from the new inclusion rate.

For corporations:
The lifetime capital gains exemption (LCGE) can be used to eliminate capital gains taxes on the sale of qualified small business corporation shares (generally, these are shares of a Canadian-controlled private corporation that carries on an active business). The LCGE is also available on the sale of qualified farm or fishing property. The current lifetime limit for the LCGE is $1,016,836. Budget 2024 proposed to increase that limit to $1,250,000 starting on June 25, 2024, so certain business owners will be able to reduce or eliminate their exposure to the new inclusion rate if they are able to make use of the increased LCGE limit.

For trusts:
Budget 2024 suggests that capital gains allocated by a trust to its beneficiaries on or after June 25, 2024, will be included in the beneficiaries’ income at the old 50% rate up to the beneficiaries’ first $250,000 of capital gains for the year. While the specifics are not yet available, this opportunity will likely create further planning considerations surrounding the allocation of capital gains from a trust to its beneficiaries to reduce taxes. Capital gains can generally be allocated to a beneficiary for tax purposes when they are actually paid to the beneficiary, or when they are payable to a beneficiary (i.e., the beneficiary hasn’t received it, but has a right to demand payment of the capital gain). The option of making income paid (or payable) to its beneficiaries and allocating such income to be taxed in their hands will largely depend on the trust terms.

Historical reference: capital gains inclusion rate
Those of us around long enough, understand that this recent change was not the only time the capital gains inclusion rate has deviated from the 50% inclusion rate. Over the years, capital gains tax rate has ranged from nil to as high as 75% as indicated in the table below. In fact, the first instance of capital gain tax was introduced in 1972!

Excluding the 2024 tax year, we have given a rough estimate on the percentage of time spent at each of the various capital gains inclusion rates over the last 42 years. As we can see, for most of the time, the capital gains inclusion rate has remained at the 50 % inclusion rate. In fact, for the last 23 consecutive years, the inclusion rate has remained untouched with the last change being back in tax year 2000 with various changes introduced that year.

Tax impact by province/jurisdiction
With the increase in the capital gains inclusion rate, we want to demonstrate the potential tax impact of those changes across jurisdictions in Canada. The table below shows the 2024 marginal tax rate for the highest individual income earners in each jurisdiction at both the 50% and 66.67% capital gains inclusion rate, respectively. The average difference is an increase in taxes payable by 8.45%.

Next, we look at the additional taxes payable because of the inclusion increase, assuming varying capital gains income levels. Of course, this assumes that the capital gains do not otherwise benefit from a reduced inclusion rate or an outright exemption such as eligible in-kind donations of securities to registered charities, or shares that qualify for the lifetime capital gains exemption, to name a few.

Understanding the tax implications of investing is an essential part of financial planning and reinforces the importance of working with a knowledgeable financial advisor to understand the long-term impact of these changes as it applies to personal situations. No doubt, tax rates influence capital allocation decisions. Canadians who take more inherent risk with their capital have traditionally been afforded preferred taxation rates promoting innovation through capital investment, something the government can do with good tax policy to encourage business growth and spur economic expansion. This is evident in the breakdown of the tax rates depending on the characterization of the income as noted in the table below.

Clearly the tax rates reflect the added capital risk investors and business owners take. We can clearly see the preferred taxation rates afforded on small business income and at the general corporate tax rates on income over the small business limit, compared to the tax rate on interest income or that of employment income. That tax-preference also extends to investors of “riskier” allocations of capital in marketable securities such as stocks, bonds, mutual funds, and exchange traded funds, to name a few. The tax rates of less-risky investments (such as money market instruments) do not benefit from the capital gains tax-preferred inclusion rates. With the latest move, there is not much difference in earning eligible dividend income from Canadian resident corporations and from dispositions resulting in capital gains.
Some pundits have declared the move as a disincentive to capital and business investment and may encourage businesses to move into more tax-favoured jurisdictions outside Canada. The Federal government has promoted the change as impacting a very small overall percentage of investors, estimated at 0.13% of Canadian individuals and 12.6% of corporations. Further, the move has been argued by the Liberals as necessary to work towards “intergenerational fairness”.

How to prepare for the changes?
For now, advisors may want to start educating their clients about the basics of the changes, which starts with comparing the current inclusion rates with the new inclusion rates.
Individual investors with large unrealized capital gains will also likely ask if they should crystallize their capital gains before June 25th to save money on taxes in the long run. The assumption that selling now will result in overall savings will not be correct in all cases, however. There is an opportunity cost to paying taxes upfront, rather than deferring those taxes to a later year.
For example, let’s assume an Ontario client owns a $2.5 million non-registered equity portfolio with $2,000,000 in unrealized capital gains. They had no intention of selling those investments for another 5 yeas, but in light of the upcoming changes, they are considering selling immediately, paying the capital gains taxes now, then reinvesting the net amount after taxes back into those same investments for the 5-year investment period. They are currently in the top marginal tax bracket in Ontario (53.53%) and expect to continue to be in 5 years’ time. The assumed average rate of return on their investments is 6% annually over the next 5 years.

As can be seen in this example, at 6% annual compound growth rate, the option to realize much of the capital gains now resulted in a higher overall return in the amount of $61,992.66 over the 5-year period due to the lower inclusion rate. Alternatively stated, if the investor does not crystallize the gains today, the equivalent rate of return needed to have the exact net after tax amount at the end of the 5-year period (the “breakeven return”) would be a 6.60% compound annual return. While this certainly will not be true in all cases, this is the sort of analysis that will have to be conducted when assessing whether it makes sense to realize capital gains in 2024. The rate of return on investment and the investment horizon, among other things, are important determining factors.

Although we used securities investment in our example, a similar analysis can be done for other kinds of property held, such as a vacation property that is unlikely to benefit from the principal residence exemption. In addition, taxes often take a back seat to other planning considerations. These conversations should be had with the primary goals of the client in mind, which may supersede tax planning considerations.

For corporate investors, it will be important to emphasize the impact the capital gains inclusion increase will have on small business owners. As a refresher, a corporation is a separate legal entity from the shareholders who own it and is subject to tax on the income it generates. Income is first taxed within the corporation before it can be passed to the shareholders in the form of dividends out of its retained earnings. To avoid double tax on income that passes through a corporation to shareholders (and to prevent any unintended tax advantages), a dividend gross-up and tax credit model is applied at the individual level, along with a tax refund mechanism to the corporation on passive investment income. This is designed to integrate the tax system between the two entities: individual and corporation. Ideally, perfect integration is achieved when after-tax income is equal, whether it is earned individually or through a corporation. In reality, depending on the province and type of income earned, there could be a tax cost in earning passive investment income through a corporation, including earning passive investment capital gains income. Currently there is a tax cost of earning capital gains income through a corporation across all Canadian provinces/jurisdictions.

The latest change further increases the cost of earning passive investment income inside a corporation, though we do not yet know what changes will be made to the corporate tax refund mechanisms. As noted in the table below, the increase averages approximately 8.43% and closely equates the rate on eligible dividends. This rate reflects the initial tax rate on passive investment income earned within an active business.

For many small businesses, and perhaps to long-term individual investors, this increase in the tax rate will feel unfair as the accumulation of earning a pool of assets for retirement is often done within their small business corporation, and in many cases the sole source of retirement funds.
If an immediate crystallization of accumulated capital gains is not desired, what should investors consider in the longer run? Although many details of the new proposed rules are yet to be clarified, here are some general considerations.
For individuals, it may be helpful to plan the timing of future dispositions to stay below the annual $250,000 threshold. Also, it may seem obvious but maximizing investments within registered plans, including the new first home savings plan (FHSA) where eligible, can reduce exposure to future capital gains tax. Moreover, estate planning becomes even more important as the potential tax payable on the deemed disposition of capital property at death rises. On that front, strategies to reduce capital gains at death could be considered, such as inter-vivos gifting, charitable donation, spousal rollover, and acquiring life insurance to provide sufficient liquidity to the estate.
For business owners, some strategies to limit future capital gain exposure may include contributing to an individual pension plan (IPP), conducting an estate freeze to pass on future capital gains to succession owners, and ensuring the small business shares qualify for the LCGE. The suitable strategies are highly dependent on the business needs and personal situation of the business owner.

Acting too soon or not fast enough?
Finally, there is what many in the industry have been calling a “change of law” risk. That is, within the next year and a half, a federal election is scheduled, and this capital gains inclusion tax policy will surely be a primary election issue. As part of that election platform, parties may promise to repeal it outright or alter its scope and application. Consider also that any changes in the capital gains inclusion rate could be retroactive or simply not apply in all cases.

The information provided is general in nature and may not be relied upon nor considered to be the rendering of tax, legal, accounting or professional advice. Invesco Canada is not providing advice. Readers should consult with their own accountants, lawyers and/or other professionals for advice on their specific circumstances before taking any action. The information contained herein is from sources believed to be reliable, but accuracy cannot be guaranteed. Commissions, trailing commissions, management fees and expenses may all be associated with mutual fund investments. Mutual funds are not guaranteed, their values change frequently and past performance may not be repeated. Please read the simplified prospectus before investing. Copies are available from your advisor or from Invesco Canada Ltd

Date posted: May 23, 2024
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