He outlined three potential government actions: abandoning the proposal, introducing it as a bill when Parliament resumes, or delaying its introduction until the 2025 budget.
He noted that retroactive application to June 25, 2024, is likely under the latter two options.
He questioned how taxpayers should handle realised or deemed capital gains in the interim. According to Moody, the Canada Revenue Agency (CRA) advises taxpayers to report gains as if the proposal is in effect to avoid interest charges if it becomes law.
However, this approach could lead to administrative issues, especially if the proposal fails to pass.
Moody also discussed a potential fifth alternative: delaying the implementation date to January 1, 2025. He noted this could reduce the administrative burden for the CRA and provide clarity to taxpayers.