Canadian Income Tax Committee

On July 21, 2026, TEI commented on the OECD's public consultation document "Revisions to Chapter VII of the OECD Transfer Pricing Guidelines: Special considerations for intra-group services." TEI's comments focused on the need for simplicity in this transfer pricing area and noted several instances where the OECD's revisions would complicate the transfer pricing of intra-group services without any corresponding benefits. TEI's comments were prepared under the aegis of its European Direct Tax Committee and were led by Ralf Thelosen of Citco. Benjamin R.

On June 11, 2026, TEI submitted comments to the Canadian House of Commons and Senate Standing Committees on National Finance regarding Bill C-31, which would significantly expand the Canada Revenue Agency's ("CRA") power to audit taxpayers. TEI's letter reiterated comments previously submitted to the Canadian government regarding why the proposed CRA audit power expansion is problematic for Canadian taxpayers - both corporate and individual - from a compliance perspective and has the potential to violate The Charter of Rights and Freedoms.

On May 11, 2026, TEI submitted recommendations to the Canadian House of Commons for improving the Canadian Income Tax Act. TEI's recommended reducing the compliance burden on corporate taxpayers by simplifying tax legislation, eliminating redundancy, and modernizing outdated tax regimes. Recommendations included streamlining the capital cost allowance system, modernizing the foreign affiliate regime, and creating a consolidated corporate tax filing.

On April 20, 2026, the Canada Revenue Agency ("CRA") responded to TEI's comments regarding the excessive interest and financing expenses limitation ("EIFEL") rules. TEI's comments addressed many EIFEL issues including excessive information reporting, unnecessary elections, and clarity regarding the many EIFEL forms. The CRA noted in its response that it had already addressed many of TEI's comments and encouraged the Institute to continue to engage with CRA on the EIFEL rules. TEI's comments were prepared under the aegis of TEI's Canadian Income Tax Committee, whose Chair is Sandy Shanks.

The Canada Revenue Agency has provided written responses to the questions posed by TEI's Canadian Income Tax Committee at their liaison meeting held on November 18, 2025.

Read Comments HERE

On September 12, 2025, TEI submitted comments to the Canadian Department of Finance regarding proposed legislation that would enhance the Canada Revenue Agency's audit powers. TEI's commented on the difficulties taxpayers would have in handling CRA requests under the new audit powers, the unfairness of newly proposed penalties in many circumstances, and how the proposed audit process under the new proposals is unclear. TEI's letter was prepared under the aegis of its Canadian Income Tax Committee, whose Chair is Sandy Shanks. Benjamin R.

On September 5th, 2025, TEI submitted comments to the Canada Revenue Agency regarding compliance with the Canadian excess interest and financing expense limitation ("EIFEL") regime. TEI's comments highlighted the unnecessary compliance costs imposed by the EIFEL reporting forms and made several recommendations about forms that could be eliminated or significantly modified. 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 August 28, 2025, TEI submitted comments to the Canadian Department of Finance regarding Canada's 2025 pre-budget consultation along with TEI's ideas for Canadian tax reform. TEI's letter was 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.

Read the comments here