Canadian Income Tax Committee

Canadian Reporting Fees for Services Initiative - TEI 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.

CRA Responds to TEI's 2023 Liaison Meeting Income Tax Questions

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.

Canadian Bare Trust Reporting - New TEI Comments

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.

Canadian Budget 2024 Expanded CRA Audit Powers - TEI 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.

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.

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