Thank you, Mr. Chair and members of the committee. Good afternoon, everyone. It's my pleasure to present to you, as you continue your pre-budget consultations.
The Canadian Dental Association is the national voice of dentistry, representing the profession and the 18,000 practising dentists in Canada, most of whom operate as small businesses, employing approximately 100,000 people and investing in their communities all across Canada.
Obviously, the discussion around the proposed changes to the Income Tax Act with regard to the Canadian-controlled private corporations provides added context in which these hearings occur. Our preference in appearing before you would have been to begin a discussion on federal leadership in funding targeted oral health programs for vulnerable populations, or to discuss increased long-term investment in programs such as the children's oral health initiative, which provides preventative oral health care for indigenous children. However, given the importance of the tax issue, I would like to spend some time discussing it.
In the CDA's pre-budget submission, we raised our concerns about the process and timeline to examine small business tax changes. At that time, we had only begun our internal discussions on that matter. Given the short timeline, with the October 2 deadline for submissions on the tax process only a few days away, we continue to consult with our members and other small business organizations to better understand the implications and the unintended consequences.
We know that these changes to tax policy will be far reaching, but the implications remain unclear and require more study. The government's discussion paper, released in July of this year, is a highly technical document. It is multi-faceted with multiple proposals. To effectively understand it's implications, more time is required on such a complex matter.
One of the biggest problems it creates is uncertainty, which is not helpful in a small business environment. Dental practices are like other small businesses. They provide middle-class jobs for tens of thousands of Canadians. They purchase supplies and equipment from Canadian suppliers. They're strong contributors to the economy, both locally and nationally. Most importantly, dental practices are like mini hospitals, requiring significant expenditures on capital equipment. Thus, like many other small businesses, the proposed tax changes could have a fundamental impact on how dental offices are established, how they're managed, and how they're staffed.
It is our view that the government's proposal takes too narrow a view of the impacts, without examining the deeper social or economic effects of such changes on small businesses and their employees. A 75-day consultation period is simply not sufficient time to properly analyze, consider the implications, and engage meaningfully with the government on these changes.
Moreover, we are concerned that some of the measures put forward in the proposal earlier this summer may make their way into the budget legislation. Including profound tax policy changes within a budget implementation bill will not allow the Standing Committee on Finance to adequately perform its duties to review the legislation, nor will it allow stakeholders to be properly consulted. We know that the committee is holding separate hearings to study these measures, and we hope those discussions will lead the government to re-evaluate its approach.
We know that the questions involved are complex and deserve an appropriate amount of study. The Canadian Dental Association would strongly recommend that the government establish a new process to allow for a more fulsome consideration of the implications of these wide-ranging proposals.
Thank you very much for your attention.