TEI files letters proposing administrative and revenue-related changes to British Columbia's provincial sales tax and carbon tax.

• Position: TECHNICAL SUBMISSIONS

TEI has filed two letters with British Columbia's Ministry of Finance proposing changes to British Columbia's provincial sales tax and carbon tax. TEI's August 31, 2015, letter, immediately preceding this, filed with the Tax Programs Branch, proposes several changes to the provincial sales tax designed to streamline tax administration for businesses and the Ministry. TEI's September 1, 2015, letter, below, filed with the Tax Policy Branch, proposes several revenue-related changes to the provincial sales tax and carbon tax to be considered in conjunction with the Ministry's annual budget process. The letters build on earlier comments made to the Ministry in letters and meetings with Ministry officials. The letters were prepared under the aegis of TEI's Canadian Commodity Tax Committee, whose chair is Richard Taylor. Canadian Commodity Tax Committee member Brian Moul and Pilar Mata, of TEI's legal staff, coordinated the development of the Institute's comments.

On April 20, 2015, several members of Tax Executives Institute, Inc.'s (TEI) Canadian Commodity Tax Committee met with representatives from the British Columbia Ministry of Finance (the Ministry) Tax Programs Branch. In that meeting, Ministry staff informed TEI that "revenue-related" changes to the Provincial Sales Tax Act (PSTA), Motor Fuel Tax Act (MFTA), Carbon Tax Act (CTA), and their regulations are made during the provincial budget process beginning in September of each year. "Administrative" changes to the PSTA, MFTA, CTA, and their regulations are made throughout the year if required.

This letter contains TEI's revenue-related comments and proposed changes to the PSTA, CTA, and their regulations, and is submitted in conjunction with the Ministry's annual budget process. TEI is concurrently submitting a separate letter to the Ministry's Tax Programs Branch outlining its "administrative" comments and proposed changes to the PSTA (copy attached).

The comments and proposed changes in this letter are not listed in order of importance. Many have been included in previous written correspondence from TEI and discussed with Ministry staff. TEI welcomes the opportunity to meet with Ministry staff to discuss these matters further.

About Tax Executives Institute, Inc.

TEI is the preeminent association of in-house tax professionals worldwide. Our approximately 7,000 members represent more than 2,800 of the leading corporations in North and South America, Europe, and Asia. TEI has over 850 members resident in Canada, which belong to chapters in Vancouver, Calgary, Montreal, and Toronto, and constitute approximately 12 percent of TEI's membership. TEI's Canadian members contend daily with the planning and compliance aspects of Canada's business tax laws. In addition, many of TEI's members resident outside of Canada work for companies with substantial activities in British Columbia and Canada. The comments in this letter reflect the views of TEI as a whole but, more particularly, those of our Canadian constituency.

1. Partnership--Person for PST Purposes Under the PSTA, a partnership can register as a collector for Provincial Sales Tax (PST) purposes, but is not treated as a separate legal person for purposes of owning partnership property. Instead, each partner is treated as if it owns a fractional interest in all of the partnerships property. This places responsibility on the partners to collect or pay PST on property...