On April 5, 2022, TEI submitted written comments to the Department of Finance concerning the government’s newly released draft legislative proposals to amend Canada’s income tax mandatory disclosure rules. These proposals were initially described in the federal budget documents tabled in Canada’s House of Commons on April 19, 2021 (“Budget 2021”), on which TEI provided preliminary feedback last fall. Consistent with our earlier submission, the enclosed comments focus intently on the perceived overbreadth of the draft proposals along with the immense compliance and administration challenges contemplated thereby.
TEI’s comments were developed jointly by a working group of concerned members under the aegis of TEI’s Canadian Income Tax Committee, whose chair is Patricia Likogiannis. Principal responsibility for drafting TEI’s comments was exercised by Watson M. McLeish, TEI Tax Counsel.