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Public Accounts committee It depends on the taxpayer. For individuals, it's three years; for large corporations, it's four years.
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee Well, I have a couple of points. First of all, your assumption, Mr. Chairman, is very much the same as our own was; that is to say, there'd be a high behavioural response to the court case finding that a certain return was tax-free. A lot of people would seek to transform their
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee The short answer is yes. In terms of the log we keep of technical amendments and concerns, there are provisions that don't get a priority because they aren't very important. Among those would be those that relate to parts of the Income Tax Act that have come and gone. I can th
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee Thank you. If I might, I would break the types of amendments or issues into two parts. Our comfort letters are our undertakings to recommend to our minister technical changes to the income tax legislation. Those letters are directed at specific taxpayers. They are almost always
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee Again, as far as the comfort letters are concerned, we would work with Canada Revenue Agency to seek to encourage them to consider that comfort letter in their debate or argument with the taxpayer, and our belief would be that Canada Revenue Agency would take the comfort letter i
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee They wouldn't in the second case--
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee In the first case, no, not necessarily. It might be a case in which they would seek to have the taxpayer file a waiver to keep the taxation year open until the comfort letter is passed.
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee Yes; it ultimately requires that Parliament enact the implementing legislation, absolutely.
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee I don't know the answer precisely, but we would hope, as a department, to be caught up this year or next.
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee Yes. To be clear, the new processes for improving the filing will, we believe, be an improvement. But it's not that the current system, at least in terms of our collating information, failed to achieve its desired purpose. Right now we have, in the old technical bill, about 100 c
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee It will of course be up to the Minister of Finance and the government as to what legislation they intend to release. What we are working to do is to prepare for the government's consideration smaller packages of technical amendments that can go forward and have us get caught up.
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee No, it is indeed expressed to have effect as of 2007 and forward. If it's enacted in that form, it would take effect from that time.
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee Forgive me, Mr. Chairman. Is this a question relating to the non-resident trust proposals again?
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee Oh, yes. I'm sorry. The point that presumably was made by witnesses from the Department of Finance at prior committee hearings about the non-resident trust and foreign investment entity rules would indeed have been that they perform a deterrent effect. We still think they will ha
March 23rd, 2010Committee meeting
Brian Ernewein
Public Accounts committee Mr. Chairman, first of all, it is the Department of Finance the reference in paragraph 3.33 refers to. Second, it did not say that it was not a priority. It said that addressing those technical legislative deficiencies was not the department's only priority.
March 23rd, 2010Committee meeting
Brian Ernewein