Canada Emergency Wage Subsidy - Canada Emergency Wage Subsidy Update ...
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the Navigator INVESTMENT, TAX AND LIFESTYLE PERSPECTIVES FROM RBC WEALTH MANAGEMENT SERVICES Canada Emergency Wage Subsidy In response to COVID-19”, the Canadian federal government has passed certain measures into law and continues to modify and propose new measures intended to stabilize the economy and provide support for Canadian workers and businesses. This Please contact us for article is an update on the Canada Emergency Wage Subsidy. more information about On March 27, 2020, the government announced a new the topics discussed in 75% temporary wage subsidy program, called the Canada this article. Emergency Wage Subsidy (CEWS), to help businesses retain employees during the COVID-19 pandemic. On April 11, 2020, Bill C-14, the COVID-19 Emergency Response Act, No.2, which included measures relating to the CEWS was passed into law. On May 15, 2020, the government announced plans to extend the CEWS qualifying period to August 29, 2020 and expanded the entities that would be eligible. On July 17, 2020, the government confirmed their previously announced intention to extend the CEWS program to December 19, 2020 and released details and draft legislation, which is now law, on how the program will apply from July 5 through November 21, 2020 (no details have been provided on how the program will work after November 21 to December 19, 2020). The effect of these new rules is that the CEWS will operate from March 15 to July 4, 2020 (4 claim periods) under the original rules discussed in this article and from July 5 to November 21, 2020 under the new rules that are discussed later in this article. Rules that apply from March eligible employee in a week, to a 15 to July 4, 2020 (claim maximum of $847 per week. Originally, periods 1 to 4) the CEWS was supposed to last for a 12 week period, beginning March The CEWS provides an eligible entity 15, 2020 to June 6, 2020. On May 15, with a wage subsidy of up to 75% 2020, the government announced of eligible remuneration paid to an that it would extend the CEWS by
2 | RBC Wealth Management an additional 12 weeks, to August 29, 2020. The rules Employees whose remuneration is eligible discussed in this section cover the claim periods from March 15 to July 4, 2020 and the changes to the rules for the subsidy are limited to individuals discussed later in this article cover the claim periods employed in Canada by an eligible entity from July 5 to November 21, 2020. The subsidy is currently that have not been without remuneration available to eligible entities whose qualifying revenue for 14 or more consecutive days in the has been reduced by at least 15% in March 2020, and at qualifying period. least 30% in April or May 2020 when compared to the same months in 2019 (the year-over-year approach) or when compared to an average of their qualifying revenue the partnership is either an Indigenous government or earned in January and February 2020 (the alternative an eligible employer will also be eligible entities for the approach). Eligible entities will need to select the year- purposes of the CEWS. Indigenous governments would over-year approach or the alternative approach when include First Nation bands, self-governing Indigenous applying for the CEWS and are required to use that same governments and other comparable Indigenous method for the entire duration of the program. Note that governing bodies; businesses that did not operate as of March 1, 2019 must use the alternative approach. ● National-level Registered Canadian Amateur Athletic Associations; Eligible entity ● Registered journalism organizations; and The CEWS is available to an eligible entity that had, on March 15, 2020, a business number registered with the ● Non-public educational and training institutions, such Canada Revenue Agency (CRA) to make remittances of as private colleges and private schools. This would employee source deductions and is include for-profit and not-for profit institutions such as arts, language, driving, flight and culinary schools. ● A taxable corporation other than a public institution (this includes public corporations and Canadian These changes will apply to the first qualifying period corporations controlled by one or more non-resident starting March 15, 2020 and subsequent qualifying periods. persons); The government also announced on May 15, 2020 that it is ● An individual; proposing to change eligibility for trusts with employees ● A registered charity or non-profit organization (other so that a trust that is a tax-exempt entity (other than a than a public institution); public institution) will be eligible for the CEWS only if it is a registered charity or one of the other types of eligible tax- ● A partnership consisting of eligible entities; or, exempt entities. Where a trust is a public institution, it will ● A prescribed organization. only qualify if it is a prescribed organization. This change applies in respect of the third qualifying period (May 10 to A public institution would generally include municipalities June 6, 2020) and any subsequent qualifying period. and local governments, Crown corporations, wholly owned municipal corporations, public universities, colleges, Eligible employees schools and hospitals. Employees whose remuneration is eligible for the subsidy are limited to individuals employed in Canada by an On May 15, 2020, the government made regulatory changes eligible entity that have not been without remuneration to prescribe certain types of organizations in order to for 14 or more consecutive days in the qualifying period extend eligibility for the CEWS to additional groups. The (known as eligible employees). Those who do not qualify prescribed organizations described below may now begin may be eligible to claim the Canada Emergency Response applying for the CEWS, provided they meet all other Benefit (CERB) for that period. For more information on eligibility criteria: the CERB, ask your RBC advisor for a copy of an article on ● Partnerships with one or more non-eligible members, this topic. provided that the total non-eligible entities’ interests in Eligible remuneration the partnership does not exceed 50% of the fair market value of all interests in the partnership at all times in the Eligible remuneration means salary, wages or other qualifying period; remuneration such as taxable benefits, as well as fees, commissions or other amounts for employment services. ● Tax-exempt Indigenous government-owned corporations It does not include a retiring allowance, severance pay or that are carrying on a business as well as their wholly items such as stock option benefits or the personal use of owned subsidiaries. Partnerships where each partner of a corporate vehicle. It also does not include any amounts
3 | RBC Wealth Management reasonably expected to be paid or repaid to the eligible On May 15, 2020, the government entity or a person not dealing at arm’s length with the announced that it intends to amend the eligible entity, or another person at the direction of the eligible entity. As well, it does not include amounts paid CEWS to allow employers to choose one of in excess of the employee’s baseline remuneration, if it is two periods when calculating the baseline expected that after the qualifying period, the employee remuneration of their employees. will be paid an amount that is lower than their baseline remuneration, and if one of the main purposes for the arrangement is to increase the wage subsidy. will also be allowed to choose to include or exclude government funding in their revenues for the purposes of The baseline remuneration for an employee was originally the revenue reduction test. based on the average weekly eligible remuneration paid between January 1 and March 15, 2020 inclusively, Revenue is to be calculated using the eligible entity’s excluding any period of seven or more consecutive days normal accounting method, which is typically but not for which the employee did not receive remuneration. always the accrual method (as revenue is earned). In recognition that the time between when revenue is earned On May 15, 2020, the government announced that it and when it is paid could be highly variable in certain intends to amend the CEWS to allow employers to sectors of the economy, eligible entities will be allowed choose one of two periods when calculating the baseline to measure their revenue on a cash basis (as revenue is remuneration of their employees. This change is intended received). If the cash method is elected, it must be used to provide flexibility for employers in determining for the entire duration of the program. remuneration for employees who were not regularly employed in early 2020, such as seasonal workers or those The legislation released on July 5, 2020 allows entities that who were on parental, disability or unpaid leave. use the cash method of accounting to elect to use accrual based accounting to compute their revenues for the Employers will be allowed to choose, on an employee-by- purpose of the CEWS.S employee basis, to calculate the baseline remuneration for an employee based on the average weekly remuneration Special rules have been provided for the calculation of paid to the employee from January 1 to March 15, 2020, or, qualifying revenue for eligible entities that may be part alternatively, the average weekly remuneration paid to the of a corporate group or joint venture. In particular, if an employee from March 1 to May 31 of 2019. In both cases, eligible entity is part of a group of eligible entities that any period of seven or more consecutive days without normally prepares consolidated financial statements, it remuneration would be excluded. may determine its qualifying revenue separately, provided that each member of the group also determines its This change applies to the first qualifying period starting revenue on that basis. As well, if an eligible entity is a March 15, 2020 and subsequent qualifying periods. member of an affiliated group of eligible entities, and Calculation of qualifying revenue each member jointly elects, the qualifying revenue of the group determined on a consolidated basis in accordance Qualifying revenue for the purpose of the revenue with relevant accounting principles may be used for reduction test means an eligible entity’s inflow of cash, each member of the group. Finally, if an eligible entity is receivables or other consideration arising in the course entirely owned by participants in a joint venture, and all of its ordinary activities (generally from the sale of or substantially all of the qualifying revenue of the eligible goods, the rendering of services and the use by others entity for the qualifying period is in respect of the joint of resources of the eligible entity) in Canada. Revenue venture, then the eligible entity may use the qualifying excludes extraordinary items and amounts derived from revenues of the joint venture (determined as if the joint persons or partnerships not dealing at arm’s-length with venture were an eligible entity). the employer. A special rule for the calculation of revenue has also been In the case of registered charities, qualifying revenue provided for an eligible entity that receives revenue from includes revenue from a related business, gifts and other a non-arm’s-length entity. If all or substantially all of an amounts received in the course of ordinary activities. For eligible entity’s qualifying revenue is from one or more other tax-exempt entities, such as non-profit organizations, persons or partnership with which it does not deal at qualifying revenue includes membership fees and other arm’s-length and each person or partnership jointly elects amounts received in the course of its ordinary activities. with the eligible entity, then the eligible entity’s revenue Both registered charities and non-profit organizations from the non-arm’s-length source may qualify as revenue
4 | RBC Wealth Management if the non-arm’s-length person or partnership experiences a revenue loss from the arm’s-length source based on the The CEWS program is distinctive to revenue reduction test mentioned above. the Temporary Wage Subsidy program enacted on March 25, 2020. This program On May 15, 2020, the government proposed to allow is discussed in more detail in a separate corporations formed on an amalgamation of two or more article on this topic. predecessor corporations (or where a corporation is wound up into another) to calculate revenue using their combined revenues, unless it is reasonable to consider that one of the main purposes of the amalgamation or 2. the amount of eligible remuneration paid up to a wind up was to qualify for the CEWS. Without this change, maximum of $847 per week or 75% of the employee’s a newly amalgamated corporation may not qualify for the “baseline remuneration”, whichever is less. CEWS since they would not have benchmark revenues to prove a revenue decline or their benchmark revenues may For those employees whose remuneration was decreased not provide a full picture of their pre-crisis revenues. This after the beginning of the COVID-19 crisis, this formula change would apply to the first qualifying period starting provides that the subsidy may effectively be as high as March 15, 2020 and subsequent qualifying period. 100% of the eligible remuneration paid to the employee for the week, subject to a maximum of $847 per week. Qualifying periods There were originally three four-week periods (the claim Based on the formula, the subsidy for a new employee period) for which an eligible entity could claim the subsidy: hired after March 15, 2020 is 75% of the amount of eligible remuneration paid, up to a maximum of $847 per week. ● March 15 to April 11, 2020 (period 1); ● April 12 to May 9, 2020 (period 2); and The subsidy amount for non-arm’s length employees will be the least of the amount of eligible remuneration ● May 10 to June 6, 2020 (period 3) paid for that week, 75% of the employee’s baseline As previously mentioned, the government announced on remuneration, and $847. This means that the subsidy May 15, 2020 that they are extending the qualifying periods would only be available in respect of non-arm’s length beyond June 6, 2020 to August 29, 2020. This added three employees employed prior to March 15, 2020. more claim periods of June 7 to July 4, 2020 (period 4), July 5 to August 1, 2020 (period 5) and August 2 to August 29, Interaction with the Temporary Wage Subsidy 2020 (period 6). Of these, only claim period 4 will follow program and work-sharing benefits the original rules. Claim periods 5 and 6, from July 5 to The CEWS program is distinctive to the Temporary Wage August 1, 2020 and from August 2 to August 29, 2020 will Subsidy program enacted on March 25, 2020. This program follow the rules announced on July 17, 2020 which are is discussed in more detail in a separate article on this discussed later on in this article. topic. If an employer claims the 10% subsidy under the Temporary Wage Subsidy program, it will reduce the Once an eligible entity is found eligible for a specific claim amount available under the CEWS, such that the maximum period, the entity will automatically qualify for the next subsidy an eligible entity can receive is 75%. As well, claim period. For example, an eligible entity with a drop employers that do not qualify for the CEWS, for example, in revenue of at least 15% in March 2020 will qualify for because they did not experience enough of a reduction the first and second claim period, covering remuneration in revenue, may still be able to qualify for the Temporary paid from March 15 to May 9, 2020. Similarly, an eligible Wage Subsidy. entity with a drop in revenue of at least 30% in April 2020 will qualify for the second and third claim period, covering The CEWS will also be reduced by amounts received by remuneration paid from April 12 to June 6, 2020. eligible employees as work-sharing benefits under the Employment Insurance Act. Amount of subsidy The amount of the subsidy available in respect of each Refund for certain employer payroll contributions eligible employee that deals at arm’s-length with the The CEWS includes a 100% refund for certain employer eligible entity is the greater of contributions to Employment Insurance (EI), the Canada Pension Plan, the Quebec Pension Plan, and the Quebec 1. 75% of the amount of eligible remuneration paid, to a Parental Insurance Plan. This refund covers 100% of maximum of $847 per week; and, employer contributions for eligible employees who are on leave with pay throughout a week (not just a portion of the
5 | RBC Wealth Management week) and for which the employer is eligible to claim the CEWS for those employees. This refund is not based on On July 17, 2020, the government confirmed the weekly maximum benefit per employee of $847 that an their previously announced intention to eligible employer may claim in respect of the CEWS. There extend the CEWS program to December 19, is no overall limit on the refund that an eligible employer 2020 and released draft legislation on how may claim. Employers are still required to continue to the program will apply from July 5 through collect and remit employer and employee contributions to November 21, 2020. each program, and would apply for a refund at the same time they apply for the CEWS. Applying for the CEWS The following highlights the changes to the existing CEWS An eligible entity must file an application with the CRA program. through the My Business Account portal as well as a web- based application. The proposed legislation announced Effective from July 5, 2020, for claim periods 5 to 9, on July 17, 2020 extends the application deadline from the CEWS will be available to an eligible entity that September 30 to December 31, 2020. The individual with experiences any decline in revenue instead of having to the principal responsibility for the financial activities of have a decline in revenue of at least 30%. This means that the eligible entity must attest to the completeness and the CEWS will now be available to more eligible entities. accuracy of the application. However, instead of the subsidy being a fixed 75% of eligible remuneration, the subsidy will consist of a variable Treatment of subsidy to employer base subsidy, for any eligible employers that experience Amounts due to the eligible entity under the CEWS are a drop in revenue and an additional top-up subsidy for deemed to give rise to an overpayment of income tax by eligible employers that experience a drop in revenue of the eligible entity. The overpayment is refundable to the more than 50%. The subsidy is calculated on a maximum eligible entity at any time during the tax year. In addition, remuneration of $1,129 per employee per week. the amount that the eligible entity receives is considered government assistance, which means it is taxable to the Qualifying periods eligible entity and would affect certain federal tax credits Here are the claim periods that these rules apply to: determined with respect to this remuneration. Of course, ● Period 5: July 5 to August 1, 2020 the eligible entity may claim a deduction for remuneration paid to their employees. ● Period 6: August 2 to August 29, 2020 ● Period 7: August 30 to September 26, 2020 Anti-avoidance measures and penalties Bill C-14 includes anti-avoidance measures targeted at ● Period 8: September 27 to October 24, 2020 eligible entities who engage in artificial transactions ● Period 9: October 25 to November 21, 2020 to reduce revenue for the purposes of claiming the CEWS. Where the anti-avoidance rules apply, the eligible Base subsidy entity is liable for a penalty that is generally equal to The maximum base subsidy will be 60% for claim periods 5 25% of the amount of the subsidy claimed, in addition and 6 and will be reached where the revenue drop is equal to the requirement to repay in full the subsidy that was to 50% or more. However, an eligible employer who would improperly claimed. have qualified for the 75% subsidy under the original rules will still be entitled to a 75% subsidy for periods 5 and 6. Rules that apply from July 5 to November 21, The maximum base subsidy will be reduced to 50% in claim 2020 (claim periods 5 to 9) period 7, 40% in claim period 8 and 20% in claim period 9. On July 17, 2020, the government confirmed their previously announced intention to extend the CEWS program to The base subsidy rate for claim period 5 and 6 will be December 19, 2020 and released draft legislation on how calculated as 1.2 x the drop in revenue up to a 50% drop (so the program will apply from July 5 through November 21, a maximum subsidy of 1.2 x 50% = 60% in period 5 and 6). In 2020 (no details have been provided on how the program claim period 7 the multiplier is 1 times the drop in revenue, will work from November 22 to December 19, 2020). On July in claim period 8 it is 0.8 and in claim period 9 it is 0.4. 20, 2020 Bill C-20, which contains this proposed legislation, was introduced in the House of Commons and received Royal Assent on July 27, 2020.
6 | RBC Wealth Management Table 1 illustrates the base subsidy rates for each claim period. Table 1 – BASE SUBSIDY RATES Period 7 Period 5 * Period 6 * Period 8 Period 9 Revenue August 30 to July 5 to August 2 to September 27 to October 25 to Drop September 26, August 1, 2020 August 29, 2020 October 24, 2020 November 21, 2020 2020 1.2 x revenue 1.2 x revenue 1 x revenue 0.8 x revenue 0.4 x revenue 0% to 49% drop drop drop drop drop 50% and over 60% 60% 50% 40% 20% Maximum weekly Up to $677 Up to $677 Up to $565 Up to $452 Up to $226 benefit per employee # * In Periods 5 and 6, employers who would have been better off under the original CEWS program in Periods 1 to 4 would be eligible for a 75% wage subsidy if they have a revenue decline of 30% or more. # This is calculated based on a maximum remuneration of $1,129 per employee per week. Top-up subsidy A top-up subsidy of up to 25% would be available to eligible employers that have experienced a 3-month average revenue drop of more than 50%. The top-up rate is equal to 1.25 times the average revenue drop that exceeds 50%, up to a maximum top-up rate of 25%. As such, an employer will receive a 25% top up if they experience a revenue decline of 70% or more. As with the base subsidy rate, the top-up rate would apply to remuneration of up to $1,129 per employee per week. The top-up subsidy rate for selected average revenue drop levels is illustrated in Table 2. Table 2 – TOP-UP SUBSIDY RATE FOR SELECTED AVERAGE REVENUE DROP LEVELS Top-up calculation = 1.25 x 3-month average revenue drop Top-up CEWS rate (3 month revenue drop – 50%) 70% and over 1.25 x (70% - 50%) = 25% 25% 65% 1.25 x (65% - 50%) = 18.75% 18.75% 60% 1.25 x (60% - 50%) = 12.5% 12.5% 55% 1.25 x (55% - 50%) = 6.25% 6.25% 50% and under 1.25 x (50% - 50%) = 0% 0%
7 | RBC Wealth Management Reference periods for the drop-in-revenues test Base subsidy For the purpose of the base subsidy, eligibility would generally be determined by the change in an eligible employer's monthly revenues, year-over-year, for the applicable calendar month. Similar to the rules for periods 1 to 4 under the original rules, if an eligible employer qualifies for one claim period they will automatically qualify for the following claim period. They would be able to use the greater of their percentage revenue decline in the current period and that in the previous period for the purpose of determining their base subsidy rate in the current claim period. Eligible employers that have elected to use the alternative approach for the first 4 claim periods would be able to either maintain that election for period 5 and onward or revert to the year-over-year approach. Similarly, employers that have used the year-over-year approach for the first 4 claim periods would be able to either continue with the year-over-year approach or elect to use the alternative approach for period 5 and onward. Whichever approach they choose would apply for claim period 5 and onward and would apply to the calculation of the base subsidy and the top-up subsidy. Top-up subsidy For the purpose of the top-up subsidy, eligibility would generally be determined by the change in an eligible employer's revenues for a 3-month period. Table 3 outlines each claim period and the relevant 3-month period for determining an eligible employer’s average change in revenue. Table 3 – REFERENCE PERIODS FOR THE TOP-UP SUBSIDY Claim period Year-over-year approach Alternative approach April to June 2020 over April to April to June 2020 average over Period 5 July 5 to August 1, 2020 June 2019 January and February 2020 average* August 2 to August 29, May to July 2020 over May to May to July 2020 average over Period 6 2020 July 2019 January and February 2020 average* August 30 to September June to August 2020 over June June to August 2020 average over Period 7 26, 2020 to August 2019 January and February 2020 average* September 27 to October July to September 2020 over July to September 2020 average over Period 8 24, 2020 July to September 2019 January and February 2020 average* October 25 to November August to October 2020 over August to October 2020 average over Period 9 21, 2020 August to October 2019 January and February 2020 average* * The calculation would equal the average monthly revenue over the 3 months of the reference period divided by the average revenue for the months of January and February 2020. Eligible employees of furloughed employees under the CEWS program Employees who are without remuneration for 14 or more by 4 weeks – from August 30 to September 26 (claim consecutive days in a period will no longer be excluded period 7). On September 25, 2020 the government again from being eligible employees, effective July 5, 2020. proposed to extend the current treatment of furloughed employees under the CEWS program by another 4 weeks Beginning in claim period 7, CEWS support for furloughed from September 27 to October 24, 2020 (claim period 8). employees (generally employees on paid leave) was to be This would mean that employers who qualify for the CEWS adjusted to align with the benefits provided through the would be able to continue to claim up to a maximum benefit CERB and/or EI. This means that their eligible remuneration of $847 per week to support remuneration for each of their would have been limited to the amount that the employee furloughed workers. Further details about the calculation of would receive under the CERB. However, on August 21, 2020 CEWS for furloughed workers for remaining periods of the the government proposed to extend the current treatment program will be announced in the coming weeks.
8 | RBC Wealth Management Eligible remuneration Other legislative amendments For active arm’s-length employees, the amount The government also made additional technical changes of remuneration would be based solely on actual that would generally apply as of March 15, 2020, some remuneration paid for the eligibility period, without of which are not discussed in this article. These include reference to the pre-crisis remuneration concept used measures relate to providing an appeals process and for earlier CEWS periods. A special rule would apply to determining revenue decline for newly-purchased active employees that do not deal at arm's length with the businesses. The government is also moving forward with employer. For period 5 and subsequent periods, the wage previously released legislative changes that are covered in subsidy for non-arm’s length employees would be based the section on rules that apply from March 15 to July 5, 2020. on the employee’s weekly eligible remuneration or pre- crisis remuneration, whichever is less, up to a maximum Conclusion of $1,129. The subsidy would only be available in respect of The CEWS rules continue to be modified and get more non-arm's-length employees that were employed prior to complex. It is important to seek professional tax advice in March 16, 2020. determining if you qualify, and if you do, the amount of the subsidy and how to apply. For period 5 and subsequent periods, the pre-crisis remuneration of an employee would be based on the This article may contain strategies, not all of which will average weekly remuneration paid to the employee apply to your particular financial circumstances. The from January 1 to March 15, 2020 or from July 1, 2019 to information in this article is not intended to provide December 31, 2019. In all cases, the calculation of average legal, tax or insurance advice. To ensure that your own weekly remuneration would exclude any period of 7 or circumstances have been properly considered and that more consecutive days without remuneration. Employers action is taken based on the latest information available, can choose which period to use on an employee-by- you should obtain professional advice from a qualified tax, employee basis. legal and/or insurance advisor before acting on any of the information in this article. This document has been prepared for use by the RBC Wealth Management member companies, RBC Dominion Securities Inc. (RBC DS)*, RBC Phillips, Hager & North Investment Counsel Inc. (RBC PH&N IC), RBC Global Asset Management Inc. (RBC GAM), Royal Trust Corporation of Canada and The Royal Trust Company (collectively, the “Companies”) and their affiliates, RBC Direct Investing Inc. (RBC DI) *, RBC Wealth Management Financial Services Inc. (RBC WMFS) and Royal Mutual Funds Inc. (RMFI). *Member-Canadian Investor Protection Fund. Each of the Companies, their affiliates and the Royal Bank of Canada are separate corporate entities which are affiliated. “RBC advisor” refers to Private Bankers who are employees of Royal Bank of Canada and mutual fund representatives of RMFI, Investment Counsellors who are employees of RBC PH&N IC, Senior Trust Advisors and Trust Officers who are employees of The Royal Trust Company or Royal Trust Corporation of Canada, or Investment Advisors who are employees of RBC DS. In Quebec, financial planning services are provided by RMFI or RBC WMFS and each is licensed as a financial services firm in that province. In the rest of Canada, financial planning services are available through RMFI, Royal Trust Corporation of Canada, The Royal Trust Company, or RBC DS. Estate and trust services are provided by Royal Trust Corporation of Canada and The Royal Trust Company. If specific products or services are not offered by one of the Companies or RMFI, clients may request a referral to another RBC partner. Insurance products are offered through RBC Wealth Management Financial Services Inc., a subsidiary of RBC Dominion Securities Inc. When providing life insurance products in all provinces except Quebec, Investment Advisors are acting as Insurance Representatives of RBC Wealth Management Financial Services Inc. In Quebec, Investment Advisors are acting as Financial Security Advisors of RBC Wealth Management Financial Services Inc. RBC Wealth Management Financial Services Inc. is licensed as a financial services firm in the province of Quebec. The strategies, advice and technical content in this publication are provided for the general guidance and benefit of our clients, based on information believed to be accurate and complete, but we cannot guarantee its accuracy or completeness. This publication is not intended as nor does it constitute tax or legal advice. Readers should consult a qualified legal, tax or other professional advisor when planning to implement a strategy. This will ensure that their individual circumstances have been considered properly and that action is taken on the latest available information. Interest rates, market conditions, tax rules, and other investment factors are subject to change. This information is not investmet advice and should only be used in conjunction with a discussion with your RBC advisor. None of the Companies, RMFI, RBC WMFS, RBC DI, Royal Bank of Canada or any of its affiliates or any other person accepts any liability whatsoever for any direct or consequential loss arising from any use of this report or the information contained herein. ®/TM Registered trademarks of Royal Bank of Canada. Used under licence. © 2020 Royal Bank of Canada. All rights reserved. NAV0268 (10/20)
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