Canadian income tax guidance priorities.

August 29, 2011

On August 29, 2011, Tax Executives Institute submitted the following recommendations to Canada Revenue Agency for establishing priorities for updating CRA's to income tax technical publications. The comments, which took the form of a letter from TEI President David M. Penney to Ren6e Shields, Manager in the Income Tax Technical Publications Section of the Canada Revenue Agency's IncomeTax Rulings Directorate, were prepared under the aegis of TEI's Canadian Income Tax Committee, whose chair is Carmine A. Arcari of The Royal Bank of Canada. Contributing substantially to the development of TEI's comments was Grant L. Lee of HSBC Bank Canada. Also contributing were Pierre Bertrand of CN Railways; Denise Couture of Suncor Energy Services, Inc.; Diana M. Morrone of Unilever Canada; and Carolyn Mulder of Wal-Mart Canada Corporation. Jeffery P. Rasmussen, TEI Senior Tax Counsel, is staff liaison to the Canadian Income Tax Committee and coordinated the preparation of the comments.

In response to your letter of June 30, 2011, to Rodney C. Bergen, the 2010-2011 Vice President for Canadian Affairs for Tax Executives Institute, I am pleased to submit the following recommendations to Canada Revenue Agency (CRA) for establishing priorities for updating its Income Tax Technical Bulletins and other guidance.

Background on Tax Executives Institute

Tax Executives Institute is the preeminent international association of business tax executives. The Institute's 7,000 professionals manage the tax affairs of 3,000 of the leading companies in North America, Europe, and Asia. Canadians constitute 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 nine geographic regions, and must contend daily with the planning and compliance aspects of Canada's business tax laws. Many of our non-Canadian members (including those in Europe and Asia) work for companies with substantial activities in Canada. The comments set forth in this letter reflect the views of the Institute as a whole, but more particularly those of our Canadian constituency.

Discussion

The dissemination of timely guidance is a critical CRA service for taxpayers and practitioners as well as for CRA's own auditors and other personnel. By summarizing and publicizing legislative, administrative, and judicial developments in Income Tax Interpretation Bulletins (ITs) and Income Tax Circulars...