Category Tax Pulse

Alternative compensation strategies to attract and retain talent

Considering the significant expense of recruiting and training employees, employers are increasingly motivated to structure compensation incentives that will not only attract top candidates, but retain them for the long term.

Strategies such as providing a supportive onboarding process, pairing new employees with mentors, conducting regular performance reviews, showing appreciation by acknowledging hard work and encouraging work‑life balance are all important elements.

But in today’s competitive market for talent, it is essential to also consider the optimum financial compensation strategy. Here, we look at a few value‑focused ways employers can compensate potential hires beyond high base salaries and benefits.

Equity‑based compensation

While smaller companies are limited when it comes to paying higher salaries, they can offer employees attractive alternative opportunities to participate in the company’s future. These are generally equity participation plans with no tangible value until they are vested. Large companies often find stock‑based plans to be an effective tool in motivating their employees, as it aligns the employee’s interests with those of the company, and the value of their efforts can be readily measured.

There are many variations in equity‑based compensation plans. These include the vesting schedule, definition of liquidity events, what happens if an employee leaves the company after options have vested and before the liquidity event, as well as other considerations. The appeal of the different plans may depend on the tax implications to both the employee and employer.

Equity‑based compensation has become commonplace as such compensation is based on an increase in the company’s share value, thereby incentivizing employees to put in greater effort to increase this value.

Stock options and warrants

Stock options or warrants are the most common non‑cash compensation plan. An employee is given the right to buy or sell the company’s stock within a certain timeframe for a specific price.

A call warrant or option grants the right to purchase shares at a specified strike price. A put warrant or option grants the right to sell the shares back to the company at a predetermined price. Each type has its own strategic implications and can be valuable, depending on the employer’s and employee’s outlook on the company’s future performance. While options and warrants have technical and legal differences, the tax implications may be similar if they are in essence received by virtue of employment.

When an employee exercises a call option, the benefit is taxable to the employee as employment income if the employee is given the right to purchase shares of the employer or a non‑arm’s length party. The benefit is also deemed to have been received if the employee transfers or disposes of rights under the agreement.

The taxation of the benefit will depend on:

  • The value of the shares at the time the options are granted;
  • The value of the shares at the time the options are exercised;
  • Amount paid by the employee for the shares (i.e., the strike price); and
  • Amount, if any, paid by the employee for the option

Generally, the employee is considered to have received a taxable benefit when the employee exercises the option and acquires the shares. The taxable benefit is the difference between the value of the shares when the employee acquired them and the amount paid for the shares, including any amount paid for the right to acquire the shares. The employee may deduct half (one‑third after June 25, 2024) of the taxable benefit if:

  • The share issued is a common share
  • The value of the share when the options are granted did not exceed the exercise price, and
  • The employer and employee are dealing with each other at arm’s length at the time the option agreement is entered into.

There is a limit of $200,000 annually of options that have vested if the employer group has revenues exceeding $500 million.

If the employer is an arm’s length Canadian‑controlled private corporation, the taxable benefit is deferred until the employee disposes of the shares. The half deduction is available if the employee holds the shares at least 2 years before selling. The stock option deduction is one‑third of the benefit if the stock option is exercised on or after June 25, 2024, or in the case of a Canadian‑controlled private corporation, when the share is sold. The deduction may be increased to half on up to a combined $250,000 for employee stock option benefit and capital gains. If the total combined employee stock option benefit and capital gains exceed $250,000, the employee may choose how to apply the $250,000.

If an employee has realized a capital gain of $125,000 and stock option benefits of $200,000 in 2025, the amount taxable at two‑thirds will be $83,333 of capital gain and $133,333 of stock option benefits.

The employee may elect to claim $200,000 of stock options and $50,000 of capital gain to be taxable at half deduction, or claim $125,000 of capital gain and $125,000 of stock options to be taxable at half deduction

An employee may receive cash instead of the shares in exchange for the option. The employee can claim the half (one‑third after June 25, 2024) deduction if eligible, or the employer can claim the cash payment as an expense, but not both.

If the employer chooses not to claim the cash‑out as an expense, the employer must elect to do so under subsection 110(1.1) of the Income Tax Act by entering this amount under code 86 ⁠–⁠ “Security options election” ⁠–⁠ in the “Other information” area of the T4 slip. This allows the employee to claim the deduction under paragraph 110(1)(d). The amount you report under code 86 may differ from the taxable benefit you must include in the employee’s income in box 14 and under code 38. If code 86 of the T4 is not entered, this indicates the employer chose to claim the expense, prohibiting the employee from claiming the deduction under paragraph 110(1)(d).

Restricted stock units

Restricted stock units (RSUs) are issued to employees through a vesting plan and distribution schedule after certain performance or service milestones are met. For example, an employee of a startup company may not receive shares as RSUs until and unless the company issues its initial public offering. Normally, no discretion or cash payment is required by the employee. RSUs are considered income once the conditions for vesting are met. Often, a number of the vested shares (if publicly traded) will be sold to cover the tax bill and the employee will only receive the balance of the shares.

Phantom stock plans

Phantom shares are a type of compensation where employees receive notional shares in the company on an established vesting schedule. Unlike RSUs, they do not provide ownership rights of actual shares. Instead, the value of the phantom stock units are tied to the company’s share value and, when vested, will be paid out in cash. For example, if an employee is awarded 100 shares when the share value is $10, and the value of the shares becomes $40 per share when vested, the benefit received is $4,000.

Stock appreciation rights

Stock appreciation rights (SARs) give employees the right to receive an amount equal to the increase in value of a set number of shares without owning them. The employee will receive a payout equal to the increase in share value. This is similar to a phantom stock plan, except it provides the right to the monetary equivalent of the increase in value of a specified number of shares over a specified time period. Using the same values as above, the employee can expect a benefit of $3,000 [($40 ‑ $10) x 1,000] at vesting.

Salary deferral arrangement

In planning equity‑based compensation arrangements, it is important to understand the salary deferral arrangement (SDA) rules. An SDA is a plan or arrangement under which an employee has a right to receive an amount in a future year where it is reasonable to consider one of the main purposes of the right is to postpone tax payable on salary or wages for services rendered by the employee in the year or a preceding taxation year. Under an SDA, the employee is taxed in the year the amount is earned.

Wondering which compensation strategy is right for you? Segal’s experts can help determine the best plan to implement, ensuring it meets the objectives of both your business and your employees.

It pays to understand compensation

The cross-border family trust

A trust is a popular tool used by taxpayers to sprinkle wealth among family members. Although in recent years the scope of the tool has been restricted, particularly in terms of the ability to income split, it is still valuable for a number of purposes, which may not be related to tax.

A simple family trust is a relationship created by a settlor, managed by a trustee who is holding property for the benefit of one or more beneficiaries, all of whom are residents of the same country. A simple family trust established by parents for family members may become a complicated family trust if the settlor, the trustee or the beneficiaries have a change of residency. These circumstances include:

  • For a Canadian trust, one or more of the beneficiaries became non‑residents
  • For a Canadian trust, due to a change of residency for the trustee(s), it is managed by a majority of non‑residents
  • A non‑resident trust with Canadian beneficiaries

Residence of a trust

The tax department considers a trust to be resident where its mind and management rests. This generally is where the decisions of the trust are made. Often, it is where the majority of the trustees reside. If resident and non‑resident trustees co‑exist, the residence of the trust will align with the person who has most or all of the powers or responsibilities, including those related to banking, financing arrangements, trust assets and reporting to the beneficiaries.

A Canadian resident trust may flow through Canadian source dividends and capital gains to its Canadian beneficiaries. It may also decide to split the tax burden between the trust and the Canadian resident beneficiaries, depending on their circumstances. However, these sources of income lose their tax beneficial treatment if paid to non‑resident beneficiaries.

If a trust ceases to be a Canadian, the trust will be deemed to have disposed of all its assets at the departure date and may realize a capital gain. If there is a tax treaty between Canada and the new country of residence, the deemed proceeds taxed in Canada may be recognized as the assets’ cost in the foreign country.

If a trust becomes a non-resident, it will likely be required to file a tax return in another country. A non‑resident trust will also be required to file a Canadian return under certain circumstances. The trust will need to ensure the double payment of tax is minimized.

Part XIII tax on distribution of income

Where any part of the income of a trust is payable to a non-resident beneficiary, the amount is subject to Part XIII withholding tax on the earlier of the day the amount was paid or credited and 90 days after the end of the trust’s taxation year. This means the tax is payable at the same time as the trust’s tax return.

Any amount paid or credited by a trust to a beneficiary is deemed to have been paid as income of the trust, regardless of the source from which the trust derived it. Even if the amount was received by the trust in a form which, if it had been paid directly to the non‑resident beneficiary, would have been exempt from withholding tax, Part XIII tax will still apply when it is paid by the trust to the non‑resident.

If the trust received capital dividends and distributed the amount to its non‑resident beneficiary, the capital dividend is subject to Part XIII tax. Such dividends would not be subject to tax if paid to the resident beneficiary.

Interest that would ordinarily be exempt from withholding tax if paid directly to the non‑resident beneficiary is subject to withholding tax if received by a trust and distributed to a non‑resident beneficiary.

Taxable capital gains of a trust that are payable to a non-resident beneficiary are subject to Part XIII tax. Even though a payment of such gains is a “payment of capital” under trust law, the CRA considers the distribution of the taxable portion to be a distribution of trust income and not capital. Therefore, it is subject to withholding tax. The non‑taxable portion of the trust’s capital gains does qualify for exemption as payment of capital.

Deemed resident trust

The deemed resident trust rules require careful analysis of all the facts and circumstances surrounding a trust.

Mr. A currently lives in the U.S., and he plans to become a resident of Canada. Before becoming resident in Canada, he made a contribution to a U.S. trust. At the time he becomes a resident of Canada, the U.S. trust will have a resident contributor and will be a deemed resident trust from the beginning of the year (not just from the time Mr. A becomes a Canadian resident).

A resident beneficiary is a Canadian resident who is a beneficiary under the trust, and there is a “connected contributor” to the trust at that time. A connected contributor is someone who has made a contribution while resident in Canada or within 60 months of moving to or leaving Canada.

Mr. B moved to the U.S. and established a U.S. trust within 60 months of leaving. The U.S. trust is for the benefit of his Canadian resident children. The trust will be deemed Canadian resident from the beginning of the year in which Mr. B made a contribution to the U.S. trust.

In addition to the above, there are many situations that may require a change in how one views the tax consequences of a trust. It is important to consult your tax advisor whenever contemplating a move to or from Canada.

Insight that follows you everywhere

Personal service corporation or the incorporated employee

The Canada Revenue Agency (CRA) is escalating its scrutiny of personal services business, and the consequences for breaching these rules can be severe. It is important, therefore, to understand these rules, to avoid falling foul of them.

A personal service corporation is a company which provides personal services, and the person who performs the work would be considered an employee of the payer if the services were provided directly. They are often referred to as incorporated employees.

Many businesses retain non‑employees to provide services to fill a short‑term need, obtain specific expertise or otherwise fill a role that is not suited to a full‑time position. There are often tax advantages to the payer to engage non‑employees instead of employees. The payer may avoid the various payroll costs such as CPP, EI, Employer Health Tax (EHT), vacation pay, etc. during the period of service and the need to pay severance on the termination of service. Administration is often limited to writing cheques based on amounts on invoices provided by the service provider.

If the CRA decides the service provider is in fact an employee, the payer may be on the hook for the employer’s and the employee’s share of payroll withholdings in addition to penalties for failing to make these withholdings. If the payer engages a corporation to provide services, the income tax risks rest mainly with the service provider. The payer is not affected by the income tax risks faced by the service providers, and the payer may prefer to or insist on dealing with corporations instead of individuals.

It appears to be advantageous to the “employee” as well. The corporation generally takes the position that it is carrying on an active business and is entitled to a low rate of tax on the first $500,000 of income. In addition, the corporation can generally deduct a wider range of expenses than those available to employees. However, if it is determined that the corporation carries on a personal services business, the corporation will be faced with negative tax consequences.

When do the personal services business rules apply?

There are four tests which must be met to trigger the personal services business rules:

  • The person providing the services must own at least 10% of the issued shares of any class of shares of the corporation or a related corporation
  • The service provider would be considered an employee of the payer, if the services are provided directly
  • The corporation does not employ more than five full‑time employees throughout the tax year
  • The corporation’s income is from services performed by the service provider on the corporation’s behalf

When the personal service business rules apply, there are two principal tax consequences. The corporation will be subject to a higher corporate tax rate on the income in addition to a limitation on the corporation’s expense deductions.

High corporate tax rate on personal services business income

The tax rate for a corporation which carries on an active business is 12.2%. For corporations earning personal services business income, the tax rate is 44.5%.

When the after‑tax corporate income is distributed to the shareholder, the shareholder will face another level of tax. If the after‑tax income were paid as an eligible dividend, the combined corporate and personal tax would be 66.3%, which is substantially higher than the tax payable by the service provider if the services were provided directly, and the top personal tax rate of 53.53% applied.

Limitation on expense deductions

If a corporation earns personal services business income, the only deductions the corporation may claim are limited to:

  • Salaries and benefits paid to the incorporated employee
  • Expenses that are allowed if the individual were a commissioned salesperson
  • Legal expenses incurred to collect amounts owing to it

All other expenses would be denied even if they were incurred to earn income.

Ways to manage your risks if you are unsure whether personal services business rules apply

  • Reduce income otherwise subject to the personal services business rules by paying out corporate earnings as salary to the service provider:
    • Only salaries that have been paid qualify as a deduction, so no deferral is available
    • Should be considered if a payer insists on working with incorporated service providers and service provider is unsure of status
  • Clearly document the relationship:
    • Make sure the intentions of both parties are clearly spelled out
    • Make sure the service provider has, to the extent possible, control over when and where the services are rendered
    • If the service provider works for more than one person
    • If the service provider provides own tools to perform the services
    • Document will form support in case of CRA challenge
  • Assess risks of treatment as personal services business in remuneration planning:
    • Salaries are deductible, whereas dividends are not
    • Dividends may be taxed as eligible dividends, but may require a late eligible dividend designation

If you have any questions, you should contact your Segal advisor to discuss how you may manage your risks.

Understand the rules, avoid penalties

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Home buyer incentives

The federal government has provided multiple financial incentives to encourage builders to build more new homes to meet the demands of both homeowners and the rental market. This includes repurposing federal land to build new homes, removing the Goods and Services Tax (GST) on new rental housing construction and additional low‑cost financing for rental housing construction. The following are additional measures intended to make home ownership more affordable and long‑term rental more available.

Crackdown on non‑compliant short‑term rentals

One of the perceived barriers to affordable long‑term rental is the proliferation of short‑term rentals such as Airbnb and Vrbo. Short‑term rentals used to be limited to 1 or more rooms in a home that were rented out by the homeowner. Now it is common to see entire homes rented out on a short‑term basis, meaning these units are removed from rental housing inventory. Many municipalities have regulations prohibiting short‑term rentals (30 days or fewer) in other than the primary home of the owner, but these rules are not always enforced.

For example, Toronto’s regulations require registration of such properties and the collection of a 6% Municipal Accommodation Tax.

No more than 3 rooms can be rented, and records must be kept as to the number of nights they are rented and the price paid. It is also necessary to keep track of whether the entire home or individual rooms have been rented.

Similar regulations exist in other Ontario municipalities.

Under rules announced in the 2023 Fall Economic Statement, short term rentals that are non‑compliant with municipal restrictions will not be able to claim rental expenses. In today’s high interest rate environment, the inability to claim expenses such as mortgage interest may be a significant deterrent to some owners and cause them to reconsider the use of the property.

The following are federal and provincial measures to ensure first‑time home ownership is more affordable. Some will be familiar to you, but others may come as a surprise.

First-time home buyer incentives

When it comes to the first‑time home buyer incentives listed below, you need to confirm you qualify as a first‑time home buyer. In Ontario, a first‑time home buyer is someone who hasn’t owned a home previously here or anywhere else in the world. If you have received your first home as a gift or inheritance, the Ontario government will not consider you a first‑time home buyer.

The requirements are different for the various tax incentives, and it is necessary to review the rules carefully to ensure you qualify.

Ontario land transfer tax rebate

If you qualify as a first-time home buyer in Ontario, you could be eligible for the provincial land transfer tax rebate. The rebate is up to $4,000 for homes priced over $368,000. The land transfer tax is not applicable for homes priced below this value. This can make quite a difference when budgeting for your new home.

To qualify for the refund, you must:

  • Be at least 18 years old
  • Be a Canadian citizen or permanent resident of Canada
  • Live in the home you’re purchasing within 9 months
  • Apply within 18 months of registration

If you’re married, you’ll also need to take into account your partner’s property history because it could affect your ability to claim the refund. If your partner acquired a home individually while you’ve been married, then neither of you would be eligible for the tax refund. But, if your partner’s property was purchased or inherited before you got married, you could still be able to claim some of the refund.

First-time home purchase rebate (Toronto)

As a first-time home buyer, you could qualify for a rebate of up to $4,475 if you're purchasing a new-build or a residential resale property in Toronto. All of the same requirements for the Ontario land transfer tax rebate apply for this rebate. It is possible to qualify for both.

The Home Buyers’ Plan

The Home Buyers’ Plan (HBP) is a program offered by the Canadian government to help first‑time home buyers get into the market. If you’re eligible, you can withdraw up to $35,000 from your Registered Retirement Savings Plan (RRSP) towards the down payment on your first home. If you and someone else are buying a home together, you can withdraw from your individual RRSPs a combined $70,000. The withdrawal is tax‑free as long as it’s paid back within 15 years, or included in income the amount which should be repaid.

To qualify for the HBP, you must:

  • Be a first-time homebuyer
  • Be a resident of Canada
  • Use the home within a year of purchasing it or building it

A first-time home buyer for the purpose of the HBP is someone who has not lived in a home you or your partner had owned in the year of purchase and the 4 prior calendar years.

The First-Time Home Buyer Incentive

The First-Time Home Buyer Incentive has been discontinued. The deadline for new or updated submissions is midnight ET on March 21, 2024. Taxpayers who are able to submit the application by March 21, 2024 may be eligible for the incentive if closing date is 6 months from time of application approval (for existing homes) or 18 months from the time of application approval (for existing home). Applications received before the deadline will be processed promptly. No new approvals will be granted after March 31, 2024.

The First-Time Home Buyer Incentive is a shared equity program with the Canadian government and can help you if you're struggling to come up with a down payment. Eligible Canadians can apply for a loan worth either 5 or 10% of a home’s purchase price, but there’s a catch.

When you eventually pay back the loan, you’ll be required to pay the equivalent of 5 or 10% of the property’s then current value. While it’s a great tool to help Canadians get into the market, the downside is you don’t know how much your home’s value will be in the future, and you will be paying the government a percentage back ⁠–⁠ not a set amount. Let’s say you purchased a home for $600,000 and borrowed 5% of the value for the down payment, which would be $30,000. You would owe the government 5% of the final sale price. So, if you held on to the home for 8 years and sold it for $950,000, you would have to pay the government back $47,500 (5% of $950,000).

First-Time Home Buyer’s Tax Credit (HBTC)

The tax credit was introduced as part of Canada’s Economic Action Plan 2009 to assist Canadians in purchasing their first home. It was created to help recover closing costs like legal expenses, inspections and land transfer taxes that can add up for first-time home buyers. The rebate amount was doubled to $1,500 in 2022 (i.e., 15% of $10,000). The credit may be split between spouses.

To qualify for the home buyers’ amount, you must:

  • Buy an eligible home
  • Include it with your personal tax return under line 31270 of your schedule 1
  • Be a resident of Canada
  • Intend to live in the home within 1 year of purchase

A first-time home buyer for the purpose of the HBTC is someone who has not lived in a home you or your partner had owned in the year of purchase and the 4 prior calendar years. You can qualify for both the HBP and the HBTC for the same home as long as you qualify under both sets of criteria.

GST/HST new housing rebate

The GST/HST new housing rebate is available to Canadians who buy a newly built home, significantly renovate an existing home or rebuild a home that was destroyed. If you qualify, the rebate allows you to recover some of the Goods and Services Tax (GST) or the federal part of the Harmonized Sales Tax (HST) you paid toward these purchases.

In addition to the various better‑known incentives described, there are other local homeowner programs offering financial assistance and support to encourage first‑time home buyers to settle in the area. Many of these programs have generous repayment terms.

Home affordability is a major issue for most new home buyers. Location of your new home may impact the incentives available, and the ultimate cost of the home. The attractiveness of the different incentives may vary depending on whether you prefer a cash rebate (generally a lower amount) instead of mortgage assistance. The cost of the home is substantially lowered if you qualify for more than one incentive. It is important to weigh these options when you decide on the affordabililty of a home. Don’t miss any incentives which you may be eligible for. Many of the programs have criteria that are independent of each other and you may be eligible for more than one.

Don't miss any incentives

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Vacant Home Tax (VHT) update for Toronto properties

In 2023, Toronto homeowners faced two sets of reporting requirements related to properties that may not have been fully occupied as residences in 2022:

  1. Reporting under the federal Underused Housing Tax (UHT)
  2. The city of Toronto’s Vacant Home Tax (VHT) Declaration

The two reporting requirements have much in common, and it’s understandable if some taxpayers are unclear about the difference between the two. In both cases, reporting is based on the previous year’s occupancy status (i.e., the 2023 filing was based on 2022 occupancy status).

There may be substantial penalties for failing to file one or both of the reports. The UHT penalty for failure to report is a minimum of $5,000 for individuals and $10,000 for other property owners. A property owner who fails to file the declaration for VHT is deemed to own a vacant home and will be assessed the VHT at 1% of the assessed value of the property, which is subject to an appeal process to have the VHT reversed.

Over the last few months, the focus had been on the Underused Housing Tax (UHT) and its 2022 filing deadline, which has been extended a number of times, most recently to April 30, 2024. It may be easy to forget the VHT declaration is about to be due. The online portal for 2024 is already live and can be used to make declarations for 2023 vacancy status.

The overview that follows will only highlight the main changes made to the VHT since last filing season.

To make the annual declaration, the owner will need a 21‑digit assessment roll number and a customer number, which can be found on your property tax bill or property tax account statement. A property that is occupied for longer than six months in the previous year by the owner or a tenant will be exempt from tax. For the upcoming 2024 filing season, a tenant includes anyone who leased the property to operate a business for a term of greater than 30 days and tenants who occupy a property as a personal residence. There are also specific exemptions to the tax, including homeowners in long‑term care, properties undergoing repairs or renovations or a vacancy caused by the death of the owner.

The requirement to satisfy the exemption for a property undergoing repairs and renovations has been changed from “obtaining an opinion from the Chief Building Official and Executive Director, Toronto Building” to a requirement that repairs or renovations are being actively carried out without unnecessary delay.

Each residential property owner must file a VHT declaration. This is different from the UHT, which exempts certain individuals (such as Canadian residents and citizens) from filing the return.

While multiple owners of one property may all have UHT filing obligations, only one VHT declaration is required for each property. It should also be noted that no VHT declaration is required if:

  • the property is not yet assessed
  • the property is classed as multi‑residential, commercial or industrial
  • the property is classified by MPAC as vacant land, parking space or a condominium locker

A new exemption is provided for newly built housing inventory that is vacant, which applies for up to two consecutive taxation years.

Owners of properties subject to the tax will be issued a Vacant Home Tax Notice at the end of March, and payment will now be due in three instalments on May 15, June 17 and July 15, 2024, rather than the earlier deadlines, which fell at the beginning of those months.

For properties in 2022 and 2023, a VHT of 1% of the Current Value Assessment (CVA) will be levied on all Toronto residences that are declared, deemed or determined to be vacant for more than six months during the previous year. For example, if the CVA of your property is $1,000,000, the tax amount billed would be $10,000 (1% of $1,000,000). To date, the UHT rate remains 1%.

For vacancies in 2024 and future taxation years, a tax of 3% of the CVA will be levied on all Toronto residences that are declared, deemed or determined to be vacant for more than six months during the previous year. For example, if the CVA of your property is $1,000,000, the tax amount billed would be $30,000 (3% of $1,000,000).

The tax is based on the property’s occupancy status and CVA for the previous year. For example, if the home is vacant in 2023, the tax will be calculated using the 2023 CVA and will become payable in 2024. If a declaration is not submitted by the deadline, the property will be deemed vacant, and it will be subject to the Vacant Home Tax. As a result, it is costly to miss the filing deadline, which has been changed from the second business day of February to the last day of February.

Effective Jan. 1, 2024, a fee of $21.24 will be charged for failing to submit a declaration of occupancy status by the declaration deadline. This fee is intended to defray the costs of administering the declaration program.

The City of Toronto has collected approximately $54 million in VHT on 2,161 declared units and 17,437 deemed vacant units. However, the numbers are expected to be lower once all the appeals in progress are resolved. Even if the assessed VHT is ultimately reversed, the appeal process is stressful and costly, making it a wise idea to file the relatively simple declaration on time.

Putting tax in perspective

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