On September 28, 2019, TEI filed comments responding to the Department of Finance Canada's Consultation Concerning the GST/HST Holding Corporation Rules, which solicits feedback on the Legislative and Regulatory Proposals Relating to the Excise Tax Act, the Excise Act, 2001 and the Air Travelers Security Charge Act. TEI's comment letter urged Finance to reject its proposed changes to the purpose test as well as its proposed change to require that companies be “closed related” rather than "related" to qualify for input tax credits under Section 186 of the Excise Tax Act. The letter further objected to excluding passive holding companies, partnerships, and trusts from Section 186's scope.
TEI's comments were prepared under the TEI's Canadian Commodity Tax Committee, whose Chair is Chantal Groulx. Committee Vice Chair, Dwaine Arnason, and TEI Tax Counsel, Pilar Mata, coordinated the preparation of TEI's comments.