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.