Canada Customs and Revenue Agency: second progress report.

On April 17, 1998, Tax Executives Institute submitted the following comments to Revenue Canada on the Canadian Government's proposal to restructure the tax agency and establish the Canada Customs and Revenue Agency. The Institute's comments took the form of a letter from TEI President Paul Cherecwich, Jr. to Herb Dhaliwal, Minister of National Revenue. The comments' preparation was coordinated by J.A. (Drew) Glennie of Shell Canada, Limited, who is TEI's representative on the Steering Committee advising Revenue Canada on the creation of the new agency, as well as by Alan Wheable of Canada Trust and Munir A. Suleman of The Bank of Nova Scotia, who are the chairs of the Institute's Canadian Income Tax and Commodity Tax Committees, respectively. TEI's previous comments on the Canadian Government's efforts to restructure Revenue Canada were reprinted in the September-October 1997 issue of The Tax Executive.

Thank you for your letter responding to comments made by Tax Executives Institute, Inc., in respect of the First Progress Report on the Government's proposal to establish the Canada Customs and Revenue Agency (hereinafter "the Agency"). In addition, under separate cover we received the Second Progress Report on the Agency and the accompanying Proposed Legislative Framework. In response to your invitation for TEI to comment on the Second Progress Report, I am pleased to submit the following.

Background

Tax Executives Institute is the principal association of corporate tax executives in North America. The Institute's 5,000 professionals manage the tax affairs of the leading 2,800 companies in Canada and the United States and must contend daily with the planning and compliance aspects of Canada's business tax laws. Canadians make up 10 percent of TEI's membership, with our Canadian members belonging to chapters in Calgary, Montreal, Toronto, and Vancouver, which together make up one of our eight geographic regions. In sum, TEI's membership includes representatives from most major industries including manufacturing, distributing, wholesaling, and retailing; real estate; transportation; financial services; telecommunications; and natural resources (including timber and integrated oil companies). The comments set forth in this letter reflect the views of the Institute as a whole, but more particularly those of our Canadian constituency.

TEI is concerned with issues of tax policy and administration and is dedicated to working with government...