On September 19, 2014, TEI submitted a letter to the Canadian Revenue Agency (CRA) and Canadian Department of Finance on proposed changes to the section 156 election for nil consideration. The election allows supplies between qualifying members of a closely related group to be made free of GST/HST. The Institute's letter welcomed the expansion of the election to include certain new members of a closely related group, and expressed concerns with new requirements that will mandate filing of all section 156 elections with CRA highlighting the associated administrative burden such a system would impose on businesses and CRA.
The letter was prepared under the aegis of TEI's Canadian Commodity Tax Committee, whose chair is Richard Taylor of Rogers Communications Inc. Contributing substantially to the development of TEI's comments were Dwaine Arnason of Shell Canada Ltd., Carole S. Levesque of Shaw Communications Inc., and Kevin Thom of ConocoPhillips Canada. Daniel B. De Jong of the Institute's legal staff coordinated the development of the Institute's comments.