Revenue Canada's proposal to increase the hourly fee for advance income tax rulings.

• Position: Brief Article

September 17, 1999

On September 17, 1999, Tax Executives Institute submitted the following comments concerning Revenue Canada's proposal to increase the hourly fee charged by the agency for advance income tax rulings. The Institute's comments took the form of a letter from TEl President Charles W. Shewbridge, III, to R.S. Biscaro, Director of Revenue Canada's Resources, Partnerships, and Trust Division. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee, whose chair is John M. Allinotte of Dofasco, Inc.

On behalf of Tax Executives Institute, Inc., I am pleased to provide the following comments in response to the invitation set forth in your letter dated June 7, 1999, to Pierre Bocti, TEI's then Vice President for Canadian Affairs. These comments relate to a proposal to increase the per-hour fee charged by Revenue Canada for Advance Income Tax Rulings.

TEI is the preeminent association of business 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. Our non-Canadian members (including those in Europe) 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.

Revenue Canada is considering whether to increase the per-hour fee charged for services rendered to taxpayers in connection with securing Advance Income Tax Rulings. Your letter explains that the fee, which was set at the current rate in 1992, would be increased from $90 to $150 per hour (plus GST). The underlying purposes for increasing the fee are to (1) recover the increased cost of providing such services and (2) afford greater resources to Revenue Canada to hire additional staff dedicated to the issuance of Advance Income Tax Rulings. With increased staff, Revenue Canada believes it will be able to increase the number of rulings issued and improve the timeliness of its response to taxpayers.

As noted, TEI's membership consists of corporate tax professionals employed by major multinational corporations. In view of the...