Canadian Income Tax Committee

On June 6, 2025, TEI submitted comments to the Canadian Prime Minister and Minister of Finance regarding proposed new Code section 899 of the One Big Beautiful Bill Act. Section 899 would impose retaliatory U.S. taxes on companies and individuals from countries that impose certain "unfair" taxes on U.S. companies and individuals, such as a digital services tax or UTPR. TEI's comments focused on the negative impact section 899 would have on Canadian companies should it be enacted into law.

On March 20, 2025, TEI submitted comments to an Expert-Sub Group of OECD Working Party 10 regarding the Working Party's GloBE Information Return XML Schema and User Guide, which was published on January 15, 2025. TEI's comments focused on the need for the OECD to provide more information about, and examples illustrating, the XML Schema and its validation rules. TEI's EMEA Direct Tax Committee led preparation of the comments. Benjamin Shreck, TEI Tax Counsel, coordinated the comment drafting process.

The Canada Revenue Agency (CRA) has responded to questions from TEI's Canadian Income Tax Committee, which were posed to the CRA at the TEI-CRA November, 19, 2024, liaison meeting.

CRA Responses to 2024 TEI Liaison Meeting Income Tax Questions

On January 20, 2025, TEI submitted comments with the Canada Revenue Agency (CRA) regarding their administration of a potential increase in the Canadian capital gains inclusion rate. TEI noted the inappropriateness of CRA administering the increase as if it has been enacted into law when it has not, as well as the complications and financial burdens imposed on taxpayers. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

On December 18, 2024, TEI submitted comments to the Canada Revenue Agency ("CRA") regarding its reporting fees for services initiative (the "Initiative"). TEI participated in the CRA's working group on the Initiative and recommended the CRA exempt from the Initiative payments to GST registrants. Other recommendations included moving from monthly reporting to yearly reporting, changing certain items on the reporting form, and raising the reporting threshold amount. TEI's comments were prepared by its Canadian Income Tax Committee, in coordination with Benjamin R. Shreck, TEI Tax Counsel.

The Canada Revenue Agency ("CRA") has submitted its written responses to TEI's December 2023 CRA-TEI liaison meeting questions regarding income taxes.

Read the responses here.

On September 11, 2024, TEI submitted comments to the Canadian Department of Finance regarding proposed amendments to the bare trust reporting rules under section 150 of the Income Tax Act. TEI's comments focused on the compliance burden the rules impose on corporate taxpayers and made several recommendations to narrow the scope of the rules. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee, whose Chair is Sandy Shanks. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

On May 29th, 2024, TEI filed comments with Canadian Minister of Finance Chrystia Freeland regarding Budget 2024's proposed expanded Canada Revenue Agency audit powers. TEI's comments focused on the substantial negative impact the proposals would have on taxpayers generally and taxpayer rights specifically. TEI's letter included several recommendations on how the expanded powers proposals could be improved and lessen their impact on Canadian taxpayers. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee, whose Chair is Steve Saunders of Atco. Benjamin R.