Lobbying registration dated 2026-03-12
Registrant: S. MICHAEL BROOKS
Client: REAL PROPERTY ASSOCIATION OF CANADA (REALPAC)
Targeted institutions:
Environment and Climate Change Canada (ECCC)
Canada Mortgage and Housing Corporation (CMHC)
Finance Canada (FIN)
Housing, Infrastructure and Communities Canada (HICC)
Prime Minister's Office (PMO)
Natural Resources Canada (NRCan)
Government funding received:
Lobbying activity details:
Advocacy with CMHC, the Federal Housing Advocate, and the Ministry of Housing regarding affordable housing programs and policies
We are working with staff on Interest Deductibility Limits (the “Proposed Interest Rules”) as proposed in the 2021 federal budget and relating to our concern that the Proposed Interest Rules may unfairly impact Canadian real estate investors, relative to both investors in other Canadian industries and investors in foreign jurisdictions (most importantly the United States (“US”))
Advocacy relating to the 2024 Federal Budget proposal to temporarily provide accelerated CCA for new eligible purpose-built rental projects, increasing the CCA rate from 4% to 10%.
Working with Natural Resources Canada and Finance Canada to create a robust Sustainable Development Strategy for Commercial Real Estate in Canada
Advocating for policy inclusions within annual budgets that improve the national commercial real estate markets. These include infrastructure enhancements, tax fairness, and energy efficiency grants.
Advocacy with Environment and Climate Change Canada relating to their Clean Electricity Regulations.
Providing input on the implementation of the Public Surplus Lands for Homes program that was announced in the Budget 2024.
Advocacy with the Department of Finance regarding Clean Technology Investment Tax Credits (applicability to real estate entities and program implementation)
Advocacy relating to the government's Budget 2024 proposal to increase the Capital Gains Inclusion Rate from one-half to two-thirds for corporations and trusts, and from one-half to two-thirds on the portion of capital gains realized in the year that exceed $250,000 for individuals, and in each case for capital gains realized on or after June 25, 2024.
Advocacy related to Budget 2025, including taxation issues, issues relevant to public capital markets, issues related to housing and housing incentive programs, issues related to GST taxation, and issues related to programs to restart the housing sector.
Advocacy with Natural Resources Canada's regarding their Energy Star Portfolio Manager Program and Green Building Strategy.
Advocacy relating to the government's possible proposal to impose an earnings-based interest deductibility limitation on Canadian corporations, including commercial real estate corporations and housing providers.
Discussions with the Ministry of Housing, Infrastructure and Communities on the development of the Renters' Bill of Rights announced in the 2024 Budget
Advocacy related to the contents of the Spring Economic Statement and particularly initiatives related to federal housing policy and the environment. These include:
- discussions around reduction in development charges through federal grants to provinces and municipalities
- reduction in the federal GST on new homes for sale
- possible financing tools to encourage new housing development
- technical amendments to the EIFEL and accelerated capital cost allowance rules for purpose-built rental
- encouraging foreign investment and speeding up development approval timelines 
- some questions around implications of the Cowichan decision in British Columbia and the Musqueam Rights Recognition Agreement on private property rights
- discussion around energy policy, decarbonization policy, and REIT legislation reform.
Advocating for policy proposals within Canada's Sustainable Development Strategy which would improve building energy efficiency.
Advocacy relating to the creation of seniors' housing real estate investment trusts vehicles that would encourage institutional investment in seniors' housing similar to existing real estate investment trust models.
Advocacy related to Budget 2024 proposal to introduce a new anti-avoidance rule that will preclude a corporation from qualifying as a “mutual fund corporation” where it is controlled by or for the benefit of certain specified groups (which may be comprised of any combination of persons that do not deal with one another at “arm’s length”).