On December 5-6, 2023, a delegation of the Canadian Commodity Tax Committee members participated in TEI's annual liaison meetings with representatives of the Canada Revenue Agency (“CRA”) and Department of Finance. The 2023 meetings featured robust agendas covering a range of tax law, policy, and administration issues of importance to many TEI members. Official written responses to many of TEI’s questions are expected from CRA.
On September 29th, TEI submitted comments to the Canadian Department of Finance regarding its proposed legislation to implement Pillar Two of the OECD's project on the taxation of the digitalization of the economy. Canada's legislation, entitled the Global Minimum Tax Act, encompasses most, but not all, of the necessary Pillar Two rules for Canada to comply with the global minimum tax regime.
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.
On December 29, 2021, TEI submitted comments to the Department of Finance Canada concerning the government’s proposal to introduce a new limitation on the deduction of business interest expense, as described in Budget 2021. Generally speaking, the proposal would limit the amount of net interest expense that a corporation could deduct in computing its taxable income to a fixed share of the corporation’s earnings.
On December 10, 2021, TEI submitted comments to the Department of Finance concerning the proposed changes to Canada’s income tax mandatory disclosure rules described in Budget 2021. TEI’s comments focus primarily on the government’s proposals to amend the Income Tax Act’s reportable transaction rules and introduce a new requirement for specified corporations to proactively report uncertain tax positions to the Canada Revenue Agency.