Thank you, Mr. Chair, and good evening. Thank you for the opportunity to present to the committee tonight.
The HCCC represents the major health charities in Canada, in key areas that include research, information, surveillance, community and patient support, and public policy.
At some point in their lives, Canadians will bear extraordinary costs to maintain their health and well-being, usually as a result of what is commonly categorized as acute illness, chronic illness, and/or disability. The Income Tax Act needs to be reviewed in terms of its language with regard to how it delivers tax relief, to determine whether it is inclusive enough of those suffering from acute or chronic disease or disability. We have a number of recommendations for your consideration.
We first recommend that the qualifying expenses list within the disability supports deduction be replaced with a general statement of principle--namely, that eligible medical expenses would include all reasonable amounts paid for goods and services that are certified as medically necessary by a qualified medical practitioner. The narrow definition of disability supports devices in section 64 should be expanded. The current list is outdated. It can't keep up with new technologies, and some equipment on the current list is no longer being used, while new and more modern equipment is not on the list. We'd also like the committee to consider treating the medical expense tax credit as a deduction as opposed to a credit, to create fairness for those suffering from chronic illnesses.
Our second recommendation is that a taxpayer should be able to pay his or her spouse, common-law partner, or some other party who is not necessarily in the business of supplying attendant care. If the spouse leaves a paid position to care for his or her spouse, he or she should be given equal treatment under the act in order to provide that care. This change would enable Canadians to obtain help and assist them in being able to work and lead productive lives while coping with their diseases. Ultimately this would reduce the burden to the health system.
Third, we need more fairness in the administration of the credit for mental or physical impairment--formerly known as the disability tax credit--since current fairness provisions are extended only to certain types of assessments. We're asking to extend it so that taxpayers can informally challenge a ruling by a CRA assessor on their disability or the requirement for special devices. This would help taxpayers, or the charities that often assist them, make their case with an advisory committee. It would extend the fairness process to the disabled, who can be subject to arbitrary rulings under the current system.
We would also like the federal government to include national health charities in the federal indirect costs of research program. The current exclusion creates an unlevel playing field for the charities that invest in research. The program unfairly penalizes national health charities and the millions of Canadians who donate to them every year. It impedes charities' ability to fund research effectively by drawing an unfair distinction between funding from government and funding from national health charities. The charities rely on the prominent research and researchers that they fund to raise the charitable dollars needed to make health discoveries and generate cures. Donors rightfully expect that their donations will be put directly towards life-saving research, not to university indirect costs. Should the charities have to pay indirect costs from donor dollars, Canadians would effectively be double-taxed, once through their tax dollars and a second time through their donations to charities.
We'd like the government to also consider investing in a publicly accessible clinical trials registry. Registration of clinical trials promotes greater accountability, transparency, and research excellence. The cost to create a Canadian clinical trials registry would be prohibitive, but international registries currently do exist. We're recommending that all clinical trials be registered through an international registry that meets the WHO requirements.
We would like to recommend that the government implement the recommendations of the Senate Standing Committee on Banking, Trade and Commerce in their special study on charitable giving, completed in the 38th Parliament. Four areas have not been implemented. First, the requirement for charities to issue charitable receipts for donations of less than $250 should be unlimited, unless specifically requested by the donor. Second, eliminate the requirement for taxpayers to file charitable receipts if the charitable donations they are claiming do not exceed $250. Third, allow donors to make charitable contributions for 60 days beyond the end of the calendar year for inclusion in that year's income tax return. And fourth, allow donors to carry back unused charitable receipts for three years and to carry forward unused charitable receipts indefinitely.
We'd also like to recommend that the government institute a fair and equitable grants and contributions program for the voluntary sector. We supported Imagine Canada's submission to the blue ribbon panel, entitled “Investing in Citizens and Communities”, and we'd like you to consider the recommendations outlined in that submission.
Thank you for your time. We've submitted a full brief for your review. If you have any questions, we'd be happy to answer them.