TEI comments on Canadian Tax restructuring proposals: August 1, 1997..

On August 1, 1997, TEI submitted comments to the Minister of National Revenue in Canada, Herb Dhaliwal, concerning the Progress Report on the Canada Customs and Revenue Agency. The Progress Report outlines the Canadian Government's proposals to restructure Revenue Canada into a single, national revenue agency with responsibility for collection of all customs, excise, and income taxes for the federal and participating provincial governments. TEI's comments were prepared under the aegis of its Canadian Income and Commodity Tax Committees, whose chairs are, respectively, Alan Wheable of Canada Rust and Munir Suleman of The Bank of Nova Scotia.

Congratulations on your recent appointment as Minister of National Revenue. Tax Executives Institute, Inc. (TEI) enjoyed a productive relationship with your predecessor, Jane Stewart, and looks forward to continuing its history of constructive interaction and exchange with Revenue Canada during your tenure as Minister. We also very much appreciate the time you devoted to meeting with representatives from three of the Institute's four Canadian Chapters on July 22, 1997, briefing them personally on the Progress Report on the Canada Customs and Revenue Agency. It is propitious that our letter of introduction to you should focus on such an important administrative matter as the Progress Report.

Background

TEI is an international organization of approximately 5,000 professionals who are responsible -- in an executive, administrative, or managerial capacity -- for the tax affairs of the corporations and the other businesses by which they are employed. TEI's members represent more than 2,700 of the leading corporations in Canada and the United States.

Canadians make up approximately 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. In addition, a substantial number of our U.S. members work for companies with significant Canadian operations. 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 submission reflect the views of the Institute as a whole, but more particularly those of our Canadian constituency.

TEI has historically been concerned with issues of tax policy and administration and is dedicated to working with government agencies in Ottawa (and Washington), as well as in the provinces (and the states), to reduce the costs and burdens of tax compliance and administration to our common benefit. We are convinced that the administration of the tax laws in accordance with the highest standards of professional competence and integrity, as well as in an atmosphere of mutual trust and confidence between business and government, will promote the efficient and equitable operation of the tax system. In furtherance of this principle, TEI supports efforts to improve the tax laws and their administration at all levels of government. As a key stakeholder of Revenue Canada, we are pleased to respond to the invitation to comment on the Progress Report of the Canada Customs and Revenue Agency.

General Comments on the Progress Report

As an organization of corporate tax professionals whose members are responsible for ensuring their companies' voluntary compliance with the nation's revenue and customs laws, TEI concurs wholeheartedly with the Progress Report's statement that:

Public confidence in the...