Submissions

On May 15, 2026, TEI submitted comments to the Government of British Columbia regarding the expansion of the provincial sales tax (PST) to certain professional services, focusing on the application to engineering services. The Canadian Commodity Tax Committee, whose chair is Martin Behagg, in coordination with TEI Tax Counsel Kelly Madigan, prepared the comments. The letter focused on the negative impacts of such an expansion and suggested targeted alternative measures.

On April 24, 2026, TEI submitted comments on Notice 2026-17, which announced the Government's intention to issue proposed regulations under section 987. The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, prepared the letter. The comments addressed timing and procedural guidance for the CFC election, how to compute and recognize the section 987 basis increase related to certain inbound transactions, and revisions for the remittance proportion formula for the equity and basis pool method.

On June 11, 2026, TEI submitted comments to the Canadian House of Commons and Senate Standing Committees on National Finance regarding Bill C-31, which would significantly expand the Canada Revenue Agency's ("CRA") power to audit taxpayers. TEI's letter reiterated comments previously submitted to the Canadian government regarding why the proposed CRA audit power expansion is problematic for Canadian taxpayers - both corporate and individual - from a compliance perspective and has the potential to violate The Charter of Rights and Freedoms.

On May 11, 2026, TEI submitted recommendations to the Canadian House of Commons for improving the Canadian Income Tax Act. TEI's recommended reducing the compliance burden on corporate taxpayers by simplifying tax legislation, eliminating redundancy, and modernizing outdated tax regimes. Recommendations included streamlining the capital cost allowance system, modernizing the foreign affiliate regime, and creating a consolidated corporate tax filing.

On April 20, 2026, the Canada Revenue Agency ("CRA") responded to TEI's comments regarding the excessive interest and financing expenses limitation ("EIFEL") rules. TEI's comments addressed many EIFEL issues including excessive information reporting, unnecessary elections, and clarity regarding the many EIFEL forms. The CRA noted in its response that it had already addressed many of TEI's comments and encouraged the Institute to continue to engage with CRA on the EIFEL rules. TEI's comments were prepared under the aegis of TEI's Canadian Income Tax Committee, whose Chair is Sandy Shanks.

On March 25, 2026, TEI submitted comments to the European Commission regarding its Call for evidence regarding an "Omnibus" on taxation to "simplify EU law and cut red tape for businesses." TEI's letter made several recommendations for tax simplification regarding anti-abuse rules, interest limitation requirements, controlled foreign company rules, as well as under the EU's parent subsidiary directive. TEI's comments were prepared under the aegis of the EMEA Direct Tax Committee and led by Ralf Thelosen. Benjamin R.

On February 10, 2026, TEI submitted comments to the European Commission regarding its "EU rules on administrative cooperation in the field of taxation – recast" consultation. TEI's comments focused on the need to simplify the reporting process in the European Union and eliminate overlap among the various anti-tax avoidance regimes. TEI's comments were prepared under the aegis of its European Direct Tax Committee. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

On December 22, 2025, TEI filed comments in response to the OECD's "Global Mobility of Individuals" consultation. TEI's comments included the need for a "one-stop-shop" approach to withholding and payment of wages and social security contributions for remote employees, prevention of "micro-PEs" when an employee works remotely from a separate jurisdiction, and the concomitant changes necessary to the OECD Transfer Pricing Guidelines. TEI's comments were prepared under the aegis of its European Direct Tax Committee.

On November 10, 2025, TEI submitted comments on the implementation of a number of the provisions in the One Big Beautiful Bill Act (OBBBA). The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, prepared the comments. The comments focused on the interaction between the Corporate Alternative Minimum Tax (CAMT) and section 174A, including a detailed discussion of the statutory grant of rulemaking authority in sections 56A(c)(15) and 56A(e) and the purposes of the CAMT.

On October 20, 2025, TEI submitted comments on Notice 2025-44, which announced the forthcoming withdrawal of final regulations regarding disregarded payments losses and related changes to the dual consolidated loss (DCL) rules, among other things. The Tax Reform Task Force, whose chair is Andreia Verissimo, in coordination with TEI Tax Counsel Kelly Madigan, prepared the comments.