On December 22, 2014, TEI submitted a letter to the Canadian Revenue Agency (CRA) listing concerns with the new filing obligations under Section 156 of the Excise Tax Act raised by TEI members that would be best addressed in the new election form and its instructions. The letter was prepared under the aegis of TEI's Canadian Commodity Tax Committee, whose chair is Richard Taylor of Rogers Communications Inc. Contributing substantially to the development of TEI's comments was Chantal Grouix of SNC-Lavalin Group, Inc. Daniel B.
On September 19, 2014, TEI submitted a letter to the Canadian Revenue Agency (CRA) and Canadian Department of Finance on proposed changes to the section 156 election for nil consideration. The election allows supplies between qualifying members of a closely related group to be made free of GST/HST.
On July 18, 2014, TEI submitted a letter to the Canadian Revenue Agency and Canadian Department of Finance expressing appreciation for proposed changes to the GST/HST joint venture election. The new rules will expand the availability of the election to all joint ventures engaged in commercial activities where all participants of the joint venture are also engaged exclusively in commercial activities.
On June 27, 2014, TEI submitted a letter to the Canadian Department of Finance observing that requiring foreign e-commerce suppliers to register with Canadian Revenue Authority and collect GST/HST on sales to final consumers would restore neutrality to the Canadian sales tax system and mitigate the pricing difference resulting from the ineffectiveness of self-assessment of the tax. The Institute's comments went on to discuss several areas to be addressed if a mandatory registration system for foreign e-commerce providers is created.
On December 7, 2012, TEI submitted a letter to the Canada Revenue Agency commending CRA for its efforts to modernize the GST/HST place of supply rules, and suggesting a number of clarifications to the CRA's draft Technical Information Bulletin that would make the document as useful, clear, and comprehensive as possible.
On March 30, 2011, TEI sent a letter to the OECD affirming direction of OECD's VAT/GST neutrality guidelines. TEI's comments were prepared by the Institute's European Indirect Tax Committee, whose chair is Jean-Daniel Rouvinez. Jeffery P. Rasmussen of the Institute's legal staff assisted with the comments.
On November 10, 2009, TEI filed comments in response to the Canada Department of Finance's release of draft legislation, explanatory notes, and a backgrounder concerning several measures aimed at improving and streamlining the application of the goods and services tax (GST) to pension plans and the financial services sector.