Thank you. My name is Debbie Pearl-Weinberg, general tax counsel at CIBC and chair of the Taxation Working Group of the Investment Funds Institute of Canada, or IFIC. I'm here representing IFIC, and my comments do not necessarily reflect the views of my employer, CIBC.
I'm joined by Barbara Amsden, director with IFIC.
IFIC is the national association of the investment funds industry. For Canadians, mutual funds lower the cost and risk of investing in securities, provide access to capital markets that was once only available to large institutional investors, and generate an important source of income, especially retirement income, for those without, and even those with, company pensions.
Eighty per cent of mutual funds in Canada are held in registered plans, RRSPs, RRIFS, and now TFSAs, and therefore the ability to save and maximize income from these plans is of primary importance to us and we believe to you.
You have our submission, so I will not repeat it, but I am going to focus on three items in the submission.
The first is addressing the new work reality. We note that while RRSPs have changed since their inception in 1957, demographics and the typical job have changed even more. While the CPP adjusts for people leaving the workforce for certain reasons by excluding the lowest years of income, there is nothing equivalent for those saving through RRSPs. It is common for people to leave the workforce for child or elder care reasons or due to job loss. They're never able to make up RRSP contributions and tax-free growth of earnings for any period without income.
Also, as more Canadians begin to work freelance or on contract, they will have widely varying incomes and they may not be able to benefit fully from RRSPs.
So our first recommendation is that the committee consider allowing RRSP contributions to be based on average income, allowing the carry forward or back of earned income above the annual limit to maximize RRSP contributions.
Second, establish greater equivalency between those in registered pension plans and those in RRSPs.
There has been a proportional decline in defined benefit pensions plans, and defined contribution pension plans have certain features that make them less attractive, especially for small businesses. At the same time, there has been a growing use of group RRSPs, but there are tax provisions that disadvantage RRSP holders. We recommend that the Income Tax Act be amended to bring Canadians with registered pension plans and RRSPs on more equal footing. For example, we suggested extending the minimum income splitting age with a spouse or partner from age 65 down to age 55 for RRIF income, consistent with rules governing registered pension plan income.
As well, we would also recommend that the pension credit be made available to those people age 55 or more who receive income from a RRIF as it is to those receiving income from a registered pension plan.
Third, we would like to address the implications of the GST and HST on mutual fund investors. It is not well understood that these economically good taxes, which generally promote competitiveness and fairness, apply in different ways to financial services and specifically in a way that taxes fund holders more heavily.
For nearly twenty years the GST has applied to mutual and other investment funds at effective rates of four to five times that of other financial products. Indeed, mutual funds were in their infancy as a retail product when the GST was introduced in the late 1980s and the rules were established.
GST at 5% may be manageable, but an HST in the double-digits makes the long-standing unequal treatment of fund holders a lot worse. This inequity is not because of the higher value added in the mutual fund where additional taxation would be expected, but because the labour and salaries that are part of delivering the financial product are fully taxable for funds, but they're tax exempt in the case of direct holdings of GICs, equity, and debt instruments.
The federal and provincial governments are studying ways to improve retirement savings, and we think Canadian fund holders should be taxed to the lower effective rate equivalent to that of other financial products in Canada and similar to the approach taken in other major value-added countries.
We appreciate the opportunity to appear before the members of the finance committee today as this is where ideas that affect the lives of millions of Canadians can receive a fair hearing and discussion.
Thank you. I would be pleased to answer any of your questions.