Bill C-48 (Historical)

Technical Tax Amendments Act, 2012

An Act to amend the Income Tax Act, the Excise Tax Act, the Federal-Provincial Fiscal Arrangements Act, the First Nations Goods and Services Tax Act and related legislation

Part 1 of this enactment implements, in accordance with proposals announced in the March 4, 2010 Budget and released for comment on August 27, 2010, amendments to the provisions of the Income Tax Act governing the taxation of non-resident trusts and their beneficiaries and of Canadian taxpayers who hold interests in offshore investment fund property.
Parts 2 and 3 implement various technical amendments in respect of the Income Tax Act and the Income Tax Regulations relating to the taxation of Canadian multinational corporations with foreign affiliates. The amendments in Part 2 are based on draft proposals released on December 18, 2009. Among other things, Part 2 includes the amendments to the foreign affiliate surplus rules in the Income Tax Regulations that are consequential to the foreign affiliate changes to the Income Tax Act announced in the March 19, 2007 Budget. The amendments in Part 3 are based on draft proposals released on August 19, 2011. Among other things, Part 3 includes revisions to the measures proposed in a package of draft legislation released on February 27, 2004 dealing primarily with reorganizations of, and distributions from, foreign affiliates.
Part 4 deals with provisions of the Income Tax Act that are not amended in Parts 1, 2, 3 or 5 in which the following private law concepts are used: right and interest, real and personal property, life estate and remainder interest, tangible and intangible property and joint and several liability. It enacts amendments, released for comments on July 16, 2010, to ensure that those provisions are bijural, in other words, that they reflect both the common law and the civil law in both linguistic versions. Similar amendments are made in Parts 1, 2, 3 and 5 to ensure that any provision of the Act enacted or amended by those Parts are also bijural.
Part 5 implements a number of income tax measures proposed in the March 4, 2010 Budget and released for comment on May 7, 2010 and August 27, 2010. Most notably, it enacts amendments
(a) relating to specified leasing property;
(b) to provide that conversions of specified investment flow-through (SIFT) trusts and partnerships into corporations are subject to the same loss utilization restrictions as are transactions between corporations;
(c) to prevent foreign tax credit generators; and
(d) implementing a regime for information reporting of tax avoidance transactions.
Part 5 also implements certain income tax measures that were previously announced. Most notably, it enacts amendments announced
(a) on January 27, 2009, relating to the Apprenticeship Completion Grant;
(b) on May 3, 2010, to clarify that computers continue to be eligible for the Atlantic investment tax credit;
(c) on July 16, 2010, relating to technical changes to the Income Tax Act which include amendments relating to the income tax treatment of restrictive covenants;
(d) on August 27, 2010, relating to the introduction of the Fairness for the Self-Employed Act;
(e) on November 5, 2010 and October 31, 2011, relating to technical changes to the Income Tax Act;
(f) on December 16, 2010, relating to changes to the income tax rules concerning real estate investment trusts; and
(g) on March 16, 2011, relating to the deductibility of contingent amounts, withholding tax applicable to certain interest payments made to non-residents, and certain life insurance corporation reserves.
Finally, Part 5 implements certain further technical income tax measures. Most notably, it enacts amendments relating to
(a) labour-sponsored venture capital corporations;
(b) the allocation of income of airline corporations; and
(c) the tax treatment of shares owned by short-term residents.
Part 6 amends the Excise Tax Act to implement technical and housekeeping amendments that include relieving the goods and services tax and the harmonized sales tax on the administrative service of collecting and distributing the levy on blank media imposed under the Copyright Act announced on October 31, 2011.
Part 7 amends the Federal-Provincial Fiscal Arrangements Act to clarify, for greater certainty, the authority of the Minister of Finance and of the Minister of National Revenue to amend administration agreements if the change in question is explicitly contemplated by the language of the agreement and to confirm any amendments that may have been made to those agreements. Part 7 also amends the Federal-Provincial Fiscal Arrangements Act and the First Nations Goods and Services Tax Act to enable the First Nations goods and services tax, imposed under a tax administration agreement between the federal government and an Aboriginal government, to be administered through a provincial administration system, if the province also administers the federal goods and services tax.
Part 8 contains coordinating amendments in respect of those provisions of the Income Tax Act that are amended by this Act and also by the Jobs and Growth Act, 2012 or that need coordination with the Pooled Registered Pension Plans Act.

Technical Tax Amendments Act, 2012

[Alain Giguère, NDP, Marc-Aurèle-Fortin, QC]

Mr. Speaker, what economic progress is he talking about?

There are more unemployed workers today than there were before the recession and even during the recession. There has been absolutely no progress made. They say they created 900,000 jobs, but they are forgetting about the 600,000 jobs lost during the recession. That leaves 300,000 jobs. What is more, jobs that paid $25 to $30 an hour have been replaced with jobs that pay $12 or $13 an hour. Is that economic progress?

Average Quebeckers have been impoverished. They have too much debt and now have to rely on food banks. With much of the Canadian population living so precariously, we cannot talk about economic growth.

[Annick Papillon, NDP, Québec, QC]

Mr. Speaker, I listened to my colleague’s excellent speech.

I still cannot fathom what Auditor General Sheila Fraser wrote in her fall 2009 report. She said that no income tax technical bill had been passed since 2001. I would point out to the House that it is now 2013.

Can my colleague explain why no income tax technical bill has been passed since 2001 even though it is now 2013? Quite frankly, that is unacceptable.

[Alain Giguère, NDP, Marc-Aurèle-Fortin, QC]

Mr. Speaker, the answer is simple and most unfortunate.

Tax fairness has never been a priority for the Liberal government or the Conservative government. Tax unfairness does not bother them in the least. That is why it took them more than 12 years to introduce tax legislation. Everyone knew it, there were red flags, and yet they did nothing. It is not because they did not know or could not do anything about it, but simply because they did not want tax fairness.

[Pierre-Luc Dusseault, NDP, Sherbrooke, QC]

Mr. Speaker, I thank my colleague for his very heartfelt speech.

He quickly mentioned that very complex tax laws benefit the wealthiest, who can afford to pay tax experts and accountants. The middle class cannot necessarily afford to pay such experts, and therefore they pay their taxes. There is no getting around it, since they cannot afford to pay a tax expert.

My colleague is an expert who has studied taxation and law. Could he talk about how complex laws often benefit the wealthiest?

[Alain Giguère, NDP, Marc-Aurèle-Fortin, QC]

Mr. Speaker, American multi-billionaire Warren Buffet said that it makes no sense that his tax rate is lower than that of an entry-level secretary at his company.

That is tax inequity. That is the problem with our tax laws. People say that when the rich get richer, they reinvest their riches. Well, unfortunately, under the George W. Bush regime in the U.S. and the Conservative regime in Canada, the idiotic application of this theory does not work.

The investments are just not there, since wealthy people do not reinvest in their own country simply because it is good to them; instead, they invest their money wherever they will make the most money. Clearly, in this case, they decided that that place was not Canada.

[Annick Papillon, NDP, Québec, QC]

Mr. Speaker, I am pleased to speak in the House in support of Bill C-48 at third reading.

This is a rather large bill that is more than 1,000 pages long. I just want to point out that Bill C-48 looks like a mammoth omnibus bill. It is a two- or three-inch-thick brick with more than 1,000 pages.

Last year, we had the mammoth Bill C-38. Then we had the mammoth Bill C-45. Now we have Bill C-48, which is extremely large and complex. What is more, the font is quite small. It is very hard to read and very complicated.

It makes many technical changes to the Income Tax Act, the Excise Tax Act, the Federal-Provincial Fiscal Arrangements Act, and other legislation. This topic may seem very technical and unappealing to many people, but these changes are often necessary and can have a significant impact on the Canadian economy. The majority of the measures proposed in this bill have already been in place for many years, but the bill makes them law.

Unfortunately, the massive size of this bill shows that there is still work to be done to convert similar technical changes into legislative measures in a timely fashion. Failure to update our tax code on a regular basis makes it hard for Canadians, business people in particular, to find any clarity in our tax system. We must also look at the growing complexity of tax law and focus on the need to simplify it over time.

The more complicated the system, the more flaws it contains, and the more room there is for loopholes. When that happens, then there are bound to people who will take advantage. That is why it is important to simplify everything.

On that subject, I would like to quote the 2012 pre-budget submission from the Certified General Accountants Association of Canada:

[We] strongly believe that the key to sustained economic recovery and enhanced economic growth lies in the government’s commitment to tax reform and red tape reduction.

CGA-Canada went on to make two recommendations. First, it recommended modernizing Canada's tax system to make it simple, transparent and more efficient. Second, it proposed implementing a “sunset provision” to prevent future legislative backlogs.

The government has been very slow to legislate technical amendments. In a report tabled about four years ago, in 2009, the Auditor General at the time, Sheila Fraser, pointed out that the Department of Finance Canada had a backlog of at least 400 technical amendments that had not been enacted. Here is what her report said:

No income tax technical bill has been passed since 2001.

It is now 2013. That means that two previous governments have been asleep at the switch, and for a considerable amount of time. Today's majority government has been in power for nearly a decade, yet an income tax technical bill has not been passed. What is it doing? We do not know.

Sheila Fraser's report goes on to say:

...the government has said that an annual technical bill of routine housekeeping amendments to the Act is desirable...

Yet we know that nothing has been introduced since 2001. They are not doing what the Auditor General suggested:

...an annual technical bill of routine housekeeping amendments...has not happened. As a result, the Department of Finance Canada has a backlog of at least 400 technical amendments that have not been enacted.... If proposed technical changes are not tabled regularly, the volume of amendments becomes difficult for taxpayers, tax practitioners, and parliamentarians to absorb when they are grouped into a large package.

At one point, people said that Beta videocassettes were the future. We no longer use videocassettes. We are making technological advances. The same thing applies to taxes. It is time for us to get up to date.

Obviously, the size of this bill and the long period of time that passed between the introduction of the previous technical bill and this one show that this process still needs improvement.

On another topic, the NDP thinks that we need to combat tax avoidance and tax evasion, while preserving the integrity of our tax system. That is why we support the changes that this bill makes, particularly those aimed at reducing tax avoidance.

However, we also believe that much more needs to be done to truly address the problem of tax evasion.

According to some estimates, the Canadian tax system is losing between $5.3 billion and $7.8 billion in revenue a year to tax evasion alone. The International Consortium of Investigative Journalists recently acquired a long list of individuals from all over the world who are holding billions of dollars in tax havens. According to the consortium, approximately 450 Canadians are on that list. We are not just making this up. We need to find out where all of this money is going.

What is more, according to the information that was recently published by Statistics Canada on foreign direct investments, Canadian investments in the top 12 tax havens worldwide exceeded $170 billion, which is equivalent to 10% of Canada's GDP.

It is true that the majority Conservative government is capable of losing track of $3 billion earmarked for public safety. As a result, it may have difficulty understanding what I am saying about tax evasion. I understand since the government has trouble implementing its own budget.

One of the main reasons why wealthy Canadians and large corporations want to put their money in tax havens is to simply avoid paying their fair share of taxes. That means billions of dollars in lost tax revenue for the federal government and fewer new jobs in Canada.

The government boasts that it has announced new investments to combat tax evasion, but unfortunately, this new money totals just one-quarter of the $113 million that this government has spent since 2009 to advertise its budgets.

Furthermore, the government has made some $250 million in cuts to the Canada Revenue Agency. These cuts led to the loss of about 3,000 jobs within that department.

The government is cutting the jobs of the people who are supposed to be working on combatting tax evasion. The Conservatives want to reduce the size of government—cut the red tape, as they say—but at what cost? They do not realize that sometimes we have to rely on the people who are able to help us. I do not think the Conservatives truly understand how important it is to combat tax evasion.

In spite of the government's lack of conviction, we believe that Bill C-48 will have a positive impact and will help discourage tax evasion.

In conclusion, the sheer size of this bill shows that the government must be more responsible in managing the tax system. More specifically, the government must ensure that it periodically passes legislation on proposed tax measures. Failure to do so creates uncertainty for business people, jurists and tax experts, and makes it nearly impossible for parliamentarians to do their jobs when they are faced with bills as big as the one we have today.

I must point out how important it is to focus on compliance to guarantee the integrity of the tax system.

The NDP believes that we must eliminate tax loopholes and work harder to combat tax havens. This government is tired and it is time for a change.

[Pierre Nantel, NDP, Longueuil—Pierre-Boucher, QC]

Mr. Speaker, I wish to congratulate my hon. colleague on her speech on a topic that is certainly not easy for everyone to understand.

My question is one that might be asked by anyone who, like me, is following events by watching the headlines and who sees that, on the one hand, the bill encompasses tax notices of the past 10 or 11 years and, on the other hand, the government is still looking for $3.1 billion.

Will this reassure the general public?

[Annick Papillon, NDP, Québec, QC]

Mr. Speaker, I thank my hon. colleague for his intervention.

I do not think this will be reassuring. In fact, nothing this government does is reassuring. I have said it before and I will keep repeating it: nothing has been done since 2001. Come on. That is embarrassing. This is a shameful time for the Parliament of Canada. Here we are and nothing has been done since 2001. Successive Liberal and Conservative governments have done nothing.

All parliamentarians should be ashamed to face Canadians and say that unfortunately we did not understand that this needed to be updated. We did not understand that tax measures needed to be introduced, that we needed to walk the talk and that we really had to tackle these issues. That is what the members opposite do not seem to understand.

[Andrew Cash, NDP, Davenport, ON]

Mr. Speaker, I thank my hon. colleague for her passion and the conviction she always brings to debate.

She was talking about fiscal responsibility and the lack of proper economic management on the government's side. We have a situation, for example, in my city in Toronto, where about 50% of all workers cannot find stable full-time jobs. That is an economic failure on the part of the federal government.

I wonder if my hon. colleague would comment on that and on whether she sees similar situations like that in her city of Québec.

[Annick Papillon, NDP, Québec, QC]

Mr. Speaker, I would like to speak for my entire region, the Quebec City area, which has experienced devastating job losses. I am particularly thinking of the Canadian Coast Guard, Parks Canada, Veterans Affairs Canada and Citizenship and Immigration Canada.

Staff cuts have been made everywhere. Then the government tried to claim that services would remain the same and nothing would change. This is simply not true.

For example, the Canada Revenue Agency, which is also in my riding, lost 3,000 employees specializing in the fight against tax evasion. These are people with a particular skill, who do this particular job for the government and for all Canadians. In a few years, the government will be greatly surprised that these measures have not worked out.

Are the Conservatives wondering why? Because government jobs were cut, that is why. We know it; everyone knows it. Now the Conservatives must understand it too. This is how we will be able to act for all Canadians.

[Alain Giguère, NDP, Marc-Aurèle-Fortin, QC]

Mr. Speaker,when I started as a young tax specialist, I was told—funnily enough—to interpret the law my way, namely in the manner most favourable to my client. I was told I should then contact various Revenue officials and send the file to the one who was most likely to agree with me. That is how it was, and how it still is, unfortunately.

The law is so complex that if you talk to different officials, you will get different answers. Will this bill change that?

[Annick Papillon, NDP, Québec, QC]

Mr. Speaker, I do not believe it will change anything because the necessary investments are not being made.

I do not know how many times I have seen a minister rise in the House and deny that there is a problem. They say that they invested a little money and that the problem will work itself out. I am sorry, but that is not the case. That is not how it works.

I do not know a lot about taxation, but I know enough to say that investing a little money will not make the system work. It takes competent people, such as legal and tax experts, people who specialize in their field. We have to trust them and believe in the work they do, not eliminate their jobs. It is important to understand that. It is fundamental.

[Joy Smith, Conservative, Kildonan—St. Paul, MB]

Mr. Speaker, I rise today to contribute to this very important discussion on Bill C-48, the technical tax amendments act, and on our government's low-tax plan for jobs, growth and long-term prosperity.

Our government, through Canada's economic action plan, is creating the winning conditions for all businesses, and the people they employ, to compete in the global economy and to continue to create jobs. We are always looking to improve on this record while, at the same time, controlling spending by federal bureaucrats and maintaining the government's commitment not to raise taxes or cut transfers to Canadians and other levels of government.

Canadians understand the importance of living within their means, and taxpayers expect the government to do the same. That is why our Conservative government is committed to managing public finances in a sustainable and responsible manner, a commitment that underpins our plan to return to budgetary balance by 2015. It is this responsible financial management that put Canada in a position of strength when it came time to combat the global recession.

From 2006 to 2008, our government paid down over $37 billion in debt, thus enabling our government to implement the stimulus phase of Canada's economic action plan without leaving our country, like many other countries, in a vulnerable fiscal position. As a result, Canada weathered the global economic and financial crisis well, particularly when compared to all other G7 countries. In the words of the noted economist Don Drummond, there is not a single developed country in the world that would not kill to have our position.

To this day, the global economic environment remains fragile. The euro area is still in recession, and uncertainty regarding U.S. fiscal policy continues to weigh on growth prospects.

While Canada's economy is expected to continue growing at a modest pace, we are not immune to external developments. In these uncertain times, we all know that the absolutely most important thing any government could do is bolster confidence and growth and maintain a strong fiscal position.

This brings me to the subject of my address today, Bill C-48, the technical tax amendments act. This is a broad and complex topic, so I will keep my remarks focused on three basic points.

I will begin by describing the highlights of Bill C-48. I will explain how it bolsters tax fairness for Canadian taxpayers. Finally, I will discuss how it maintains the competitive nature of the Canadian legal jurisdiction.

We have legislation before us today that takes further action to strengthen Canada's tax system. We must ensure its swift passage. I urge all my colleagues on the other side of the House to get on board and help us ensure tax fairness for all Canadians, just as members of the finance committee did earlier this year.

As Mr. Lorne Shillinger of KPMG said, “Whatever the process is of getting this bill enacted, stick to it, full speed ahead”.

I could not agree more. Let us pass this legislation so that all Canadians benefit.

As an overview, let me note that this bill will amend the Income Tax Act, the Excise Tax Act and related legislation to close tax loopholes and create a stronger and fairer tax system for all Canadians. The bill contains proposals that have been public for many years and was the subject of numerous, wide public consultations. Therefore, the bill is not new to the House. I want to note that the proposals in the bill represent the feedback from those numerous public consultations. Even better, they all aim to ensure that everyone pays their fair share of tax and is treated equitably under our tax laws.

As the legislation is quite technical in nature, I will be brief in my summary of its highlights.

In part 1 of Bill C-48, our government proposes enhancements to the Income Tax Act to better target and simplify those rules relating to non-resident trusts, taking into account comments received during those public consultations I was speaking of.

Parts 2 and 3 relate to the taxation of Canadian multinational corporations in respect of their foreign affiliates. Once again, our government consulted extensively with the public and stakeholders on these proposals with the objective being the creation of a fair and more equitable international tax system.

Part 4 of Bill C-48 would ensure that the tax rules work well under both common and civil law.

Part 5 of the bill would close tax loopholes and create greater fairness for taxpayers. Indeed, this portion of the bill would implement a number of integrity tax measures from 2010, on which we have consulted widely, to address any issues that may exist.

These particular measures would, first of all, close tax loopholes relating to a specified leasing property. We have heard that before in this House. Second, they would ensure that conversion of specified investment flow-through trusts and partnerships into corporations would be subject to rules similar to those for transactions between corporations. Third, they would prevent schemes designed to artificially increase foreign tax credits in order to reduce tax. Finally, they would implement a regime for information reporting of tax avoidance transactions. These are very important. Taken together, these measures would help crack down on tax avoidance and ensure that everyone pays their fair share of tax.

Part 5 also includes a number of technical changes that are designed to ensure that the income tax system functions in accordance with its underlying policy intent. Many of these changes would address issues identified by taxpayers themselves in the course of working through the application of the income tax rules to their own situations.

I cannot stress enough how important it is that this legislation be passed. Implementing these technical changes responds to both the 2009 Auditor General's report and the 12th report of the Standing Committee on Public Accounts.

The Auditor General's report highlighted the importance of implementing technical amendments to give certainty to taxpayers and to the Canada Revenue Agency. The report recommended that technical measures be released on a regular basis. Indeed, Ms. Vicky Plant, Principal in the Office of the Auditor General of Canada, said this to the finance committee: “Mr. Chair, when the Department of Finance determines that some changes have to be made to the Income Tax Act, it is important that legislative changes be tabled in the House of Commons promptly”.

With this legislation, our government had done so. The report of the Standing Committee on Public Accounts I just mentioned that once technical bills have been tabled, it is up to Parliament to ensure that they are passed.

It is not only the standing committee that feels that it is important for Parliament to pass this legislation. I will read a few quotes from tax experts who appeared at the finance committee earlier this year and pleaded for the swift passage of Bill C-48.

Kim Moody, of Moodys LLP Tax Advisors, said: “[O]ur firm supports the passage of Bill C-48.... [I]t is important to get it passed”.

Greg Boehmer, of Ernst and Young, said: “[W]e greet Bill C-48 with a sense of relief and hope to see its speedy passage”.

Andrew Kingissepp, of Osler, Hoskin and Harcourt LLP, said: “I would encourage all parties to enact this proposed legislation into law at the earlier opportunity”.

I again implore my colleagues across the way to ensure that Bill C-48 passes swiftly. It is critical to the integrity of the tax system that we do just that as parliamentarians in this House.

Not only does Bill C-48 respond to the above-mentioned reports, but it achieves other goals as well. Part 5 implements an income tax amendment relating to the enactment of the fairness for the self-employed act. It provides a tax credit in respect of employment insurance premiums paid by self-employed individuals. Part 6 of Bill C-48 implements technical amendments to the GST-HST, including relieving the GST-HST on the administrative service of collecting and distributing the levy on blank media imposed under the Copyright Act. This is very important.

Part 7 amends the Federal-Provincial Fiscal Arrangements Act and the First Nations Goods and Services Tax Act to provide for technical changes concerning tax administration agreements. Finally, part 8 coordinates amendments that ensure that the tax amendments in Bill C-48 interact properly with all other legislation. As all of the measures in the legislation have been examined in greater detail by the finance committee, I wish to emphasize that the underlying goal of this legislation is to simplify the tax system, make it easier to comply and administer, and create more fairness for all Canadian taxpayers.

Ensuring that everyone pays their fair share helps to keep taxes low for everyone and it improves incentives to work, save and invest. It attracts companies to our country. It attracts business in Canada. This is very important. Allow me to quote Mr. Larry F. Chapman, executive director and chief executive officer of the Canadian Tax Foundation, who stated to the Standing Committee on Finance earlier this year:

Bill C-48, the Technical Tax Amendments Act, 2012, the so-called tech bill, is a massive piece of legislation....but it represents 10 years of repairs and maintenance in updating the Income Tax Act and the Excise Tax Act.

When members opposite stood in the House and showed the massive tax act bill, this is what this gentleman was referring to. It is a massive piece of legislation and represents 10 years of repairs and maintenance in updating the Income Tax Act and the Excise Tax Act.

He further stated:

Its passage is important to all Canadians... I want to emphasize it again. Its passage is very important to all Canadians.

They are awaiting its passage in Parliament, waiting for parliamentarians to do the right thing.

All of us as taxpayers are obligated to provide a portion of our hard-earned incomes to fund health care, social programs and other vital services to Canadians. We do so willingly and honestly, asking only in return that governments both manage our tax dollars wisely and ask no more from us than our fair share. Canadians can count on our government to do both.

I hope all members in the House who were elected would commit to that basic fundamental principle of paying their fair share of taxes. It is troublesome when we hear of members who have not done that. Broadening and protecting the tax base supports the government's efforts to return to balanced budgets, responds to provincial governments' concerns about protecting provincial revenues on a shared tax basis and helps give Canadians confidence that our tax system is fair.

As part of the government's continuing commitment to keep taxes low for Canadian families and to ensure the integrity of the tax system, I am happy to report that economic action plan 2013 proposes a number of measures to close tax loopholes, address aggressive tax planning, clarify tax rules and reduce international tax evasion and aggressive tax avoidance. Members on all sides of the House have mentioned this. The government is committed to closing tax loopholes that allow a select few businesses and individuals to avoid paying their fair share. Ensuring that everyone pays their fair share also helps to keep taxes low for Canadian families and businesses, thereby improving incentives to work, save and invest in Canada.

Since 2006, including measures proposed in economic action plan 2013, the government has introduced over 75 measures to improve the integrity of the tax system. The government is taking steps in economic action plan 2013 to improve the integrity of the tax system in several ways, such as further extending the application of Canada's thin capitalization rules to Canadian resident trusts and non-resident entities; ensuring that the lost pools of trust cannot be inappropriately traded among arm's-length persons; enhancing corporate anti-loss trading rules to address planning that avoids these rules; ensuring that derivative transactions cannot be used to convert fully taxable ordinary income into capital gains taxed at a lower rate; eliminating unintended tax benefits relating to leveraged, insured annuities; and eliminating unintended tax benefits relating to leveraged life insurance arrangements, commonly known as the 10/8 arrangements.

These are but a few of the improvements that are being proposed here today. In addition, economic action plan 2013 will provide the Canada Revenue Agency with new tools to enforce the tax rules to reduce international tax evasion and aggressive tax avoidance such as extending the normal reassessment period by three years for taxpayers who have failed to report income from a specified foreign property on their annual income tax return and failed to properly file the foreign income verification statement known as form T1135. This does happen quite legitimately sometimes, but it has to be addressed. Other tools include revising of form T1135 to require reporting of more detailed information; streamlining the process for the CRA to obtain information containing unnamed persons from third parties such as banks; requiring certain financial intermediaries, including banks, to report to the CRA their clients' international electronic funds transfers of $10,000 or more; and announcing the CRA's new stop international tax evasion program that will pay rewards to individuals with knowledge of major international tax non-compliance.

While ensuring its integrity and fairness, our government continues to work hard to ensure that the tax system remains competitive so that we attract new business investment in the Canadian economy that creates jobs that Canadian families depend on. Lower taxes play a particularly important role in supporting economic growth by enabling businesses to invest more of their revenues back into their operations. These business investments in machinery, equipment, information technology and other physical capital will boost Canada's productivity and help Canadian businesses grow and create more jobs.

As we all know, our government's tax changes have greatly improved Canada's business environment and tax competitiveness. Canada now has the lowest overall tax rate on new business investment in the G7. Our government recognizes that low taxes increase the productive capacity of the Canada economy as well as Canadian living standards. It is this productivity growth that allows businesses to hire additional workers or offer higher wages to expand production and earn more profits.

Our government is committed to lower taxes for all Canadians. That is why, since coming to office in 2006, we have introduced broad-based tax relief such as lowering the GST rate from 7% to 5% and introducing the tax-free savings account. In total, we have introduced more than 150 tax relief measures. Canadians at all income levels are benefiting from tax relief introduced by our government, with low-income and middle-income Canadians receiving proportionately greater relief. Indeed, more than one million low-income Canadians have been removed from the tax rolls. Our strong record of tax relief is saving the typical Canadian family of four more than $3,200 a year.

The legislation before us today takes us even further toward this tax fairness objective. Once again, I encourage the NDP and Liberals to support this important legislation and to help create greater tax fairness for all Canadians.

[Andrew Cash, NDP, Davenport, ON]

Mr. Speaker, my hon. colleague talked about how having the lowest business taxes in the G7 allows businesses to hire. Could she explain this to all the young people in Toronto and across the country who cannot find any kind of permanent job? In fact they are relegated to an endless cycle of unpaid internships and short-term contract employment. In Toronto right now the official unemployment rate for young people is above 15%, but we know that the unofficial rate is well above that. It is over 20%. What can the member say to young people about the government's abysmal record on job creation for young people? It is in the statistics. It is not in the speaking notes, but the stats are there.

[Joy Smith, Conservative, Kildonan—St. Paul, MB]

Mr. Speaker, the member opposite is obviously very concerned about his riding. Therefore, I would hope that he would give new hope to those young people who are looking for jobs and tell them that now, in spite of the economic climate globally, our country is the most sought after country in terms of economic climate in the world. There are 900,000 net new jobs that have been created.

I think it is a really good idea not to say to our youth that our country is no good and nothing is going right in our country when actually it is the envy of the world. Those 900,000 new jobs are very important for these young people and they can get out and get them.