Priority updates for Canadian interpretation bulletins and information circulars.

On February 18, 2008, TEI President Robert J. McDonough submitted recommendations to Canada Revenue Agency for updates to CRA's interpretation bulletins and information circulars. The recommendations were prepared under the aegis of TEI's Canadian Income Tax Committee, whose chair is David M. Penney of General Motors of Canada Limited.

In February 2007, Tax Executives Institute wrote to urge that Canada Revenue Agency (CRA) resume its practice of regularly updating its interpretation bulletins (ITs) and information circulars (ICs) and issuing new ITs and ICs as warranted by legislative, administrative, and judicial developments. On behalf of the Institute, I am pleased to submit the following recommendations for CRA in establishing its priorities for updating the myriad ITs and ICs.

Background

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

As noted in TEI's February 2007 letter, the dissemination of timely guidance is a critical CRA service for taxpayers and practitioners. By summarizing and publicizing legislative, administrative, and judicial developments in ITs and ICs, CRA assists taxpayers in understanding and complying with their tax reporting and payment obligations and affords tax professionals the information necessary to tailor advice to their clients' facts and circumstances.

Subsequent to the submission of TEI's letter, we understand that CRA decided to allocate resources to its publication division in order to resume issuing ITs and ICs. We commend CRA for its decision. To assist CRA in establishing priorities for updating the ITs and ICs, TEI's Canadian Income Tax Committee has reviewed all extant interpretations and circulars and developed the attached list of topics where...