TEI Comments on Canadian Interest & Financing Limitation
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.
TEI Submits Comments on Canadian 2025 Pre-Budget Consultation and Tax Reform
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
Canadian 2025-26 Pre-Budget Finance Committee Consultation - TEI Comments
On July 31, 2025, TEI submitted recommendations to the Canadian House of Commons' Standing Committee on Finance regarding its pre-Budget consultations for the 2025-26 fiscal year. TEI recommended the Canadian government conduct a comprehensive review of (i) the tax compliance burden faced by Canadian taxpayers; (ii) the income tax audit process, from the start of the audit itself through to the appeals and dispute resolution process; and (iii) the overly complex and burdensome foreign affiliate taxing and reporting regime.
Canadian Capital Gains Tax Increase - TEI Comments
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.
TEI Holds 2021 Virtual Liaison Meetings with Canada Revenue Agency and Department of Finance
TEI Holds 2015 Liaison Meetings with Canada Revenue Agency and the Canadian Department of Finance
On November 17-18, 2015, representatives from Tax Executives Institute, led by 2015-2016 Vice President for Canadian Affairs Lynn Moen, met with officials from Canada Revenue Agency and the Canadian Department of Finance to discuss tax policy and administrative matters.
The agendas for the meetings on income tax matters were prepared by the Institute's Canadian Income Tax Committee, whose 2015-2016 chair is Grant L. Lee of HSBC Bank Canada. John Schoenecker of the Institute's legal staff coordinated the preparation of its agendas.
TEI Comments on Proposed Canadian Legislation Effecting Reporting of Qualified Non-Resident Employees
On October 12, 2015, TEI submitted a letter to the Canadian Department of Finance suggesting further legislative changes surrounding Regulation 102 in the form of (1) allowing self-certification as to “qualifying non-resident employer” status and (2) eliminating the $10,000 threshold for T4 reporting requirements. The proposed legislation would require employers to obtain advance certification from the CRA before being considered a “qualifying non-resident employer” as well as reporting on form T4 of all “qualifying non-resident employees” who make more than $10,000.
TEI Comments on Proposed Canadian Legislation Effecting Income Tax Act Section 55
On October 12, 2015, TEI submitted a letter to the Canadian Department of Finance stating that a proposed expansion of the Income Tax Act's subsection 55(2), which is an anti-avoidance provision, would unduly apply to routine transactions that have no anti-avoidance purpose. The proposed legislation would expand the “purpose test” to capture instances in which dividends are paid on a share, not to reduce a capital gain, but instead to (i) significantly decrease the fair-market value of any share, or (ii) significantly increase the total property costs to the dividend recipient.
TEI Holds 2014 Liaison Meetings with Canada Revenue Agency and Canada Department of Finnace
On November 18-19, 2014, representatives from Tax Executives Institute, led by 2014-2015 President Mark C. Silbiger and 2014-2015 Vice President for Canadian Affairs Paul T. Magrath, met with officials from Canada Revenue Agency and the Canadian Department of Finance to discuss tax policy and administrative matters.
TEI Holds 2013 Liaison Meetings with Canada Revenue Agency and the Canadian Department of Finance
On December 3-4, 2013, representatives from TEI, led by 2013-2014 Vice President for Canadian Affairs Shiraz J. Nazerali, met with officials from Canada Revenue Agency and the Canadian Department of Finance to discuss tax policy and administrative matters.