Canadian Income Tax

TEI’s Canadian Income and Commodity Tax Committees Seek Member Input for 2021 Liaison Meetings

The members of TEI’s Canadian Income Tax and Canadian Commodity Tax committees are actively preparing for the Institute’s 2021 liaison meetings in Ottawa, and they seek your input in developing this year’s meeting agendas.

CANADIAN INCOME TAX

Staff Liaison:

Ben Shreck, Tax Counsel
202.464.8353

 

CRA Responds to TEI's Questions from December 2022 Liaison Meetings

The Canada Revenue Agency ("CRA") has submitted its written responses to TEI's December 6, 2022, CRA-TEI liaison meeting questions.

Read the responses here.

CRA Responds to TEI's Questions from December 2021 Liaison Meetings

The Canada Revenue Agency ("CRA") has submitted its written responses to TEI's December 7, 2021, CRA-TEI liaison meeting questions.

Read the responses here.

CRA Responds to TEI's Questions from December 2020 Liaison Meetings

The Canada Revenue Agency ("CRA") has submitted its written responses to TEI's December 8, 2020, CRA-TEI liaison meeting questions.

Read the responses here.

Canadian Bare Trust Reporting - TEI Comments

On September 27th, 2023, TEI submitted comments to the Canada Revenue Agency regarding new rules for reporting "bare trusts arrangements." TEI's comments focused on the compliance burden the new rules would impose on corporations and other businesses, which in most cases would be duplicative of other reporting requirements already imposed on such entities, among other things. TEI's comments were prepared by its Canadian Income Tax Committee, whose Chair is Steve Saunders of Atco. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

Canadian EIFEL Rules - TEI Comments

On September 13, 2023, Tax Executives Institute, Inc. ("TEI") submitted comments to the Canadian Department of Finance regarding proposed legislation that would implement an excessive interest and financing expenses limitation ("EIFEL"). TEI's comments addressed the proposed implementation date of the EIFEL rules, the need to except existing debt obligations from the rules for a period of time, and issues surrounding the group ratio election, among other things. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee. Benjamin R.

Proposed Canadian GAAR Penalty - TEI Comments

On September 8, 2023, Tax Executives Institute, Inc. ("TEI") submitted comments to the Canadian Department of Finance regarding the Department's proposed tax penalty for transactions held subject to Canada's General Anti-Avoidance Rule ("GAAR"). TEI's comments focused on the need for the GAAR penalty to have a true due diligence defense to its imposition and include a significant fault requirement, both are which are necessary to avoid having taxpayers report all their transactions so as not to be subject to the penalty.

Canadian RUTT Form - TEI Comments

On June 7, 2023, TEI submitted comments to the Canada Revenue Agency ("CRA") regarding the draft Reportable Uncertain Tax Treatment ("RUTT") form. Taxpayer must use the RUTT form to report certain items depending on how those items are treated on a taxpayer's relevant financial statements. TEI's comments focused on recommendations to reduce the burden of preparing and filing the RUTT form with CRA, including limiting the information the form requires, filing the form by a single entity within a consolidated group, and clarifying which taxes the RUTT form encompasses.

Certain Aspects of OECD Pillar Two - TEI Comments

On August 14 2023, TEI submitted comments to the OECD regarding certain aspects of the OECD's Pillar Two initiative. TEI's comments were provided as a follow up to the Institute's June 6 meeting with representatives from the OECD. The Institute's comments focused on issues arising from disputed tax amounts, administration of the GloBE information return, as well as the various Pillar Two safe harbors. The Institute's comments were led by TEI's EMEA Direct Tax Committee. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of the Institute's comments.

Close