Chair and members, thank you very much for inviting us to discuss Bill C-86.
There are many positive initiatives in this bill that we are very supportive of, but we are concerned that too many seem half finished and are not fully developed.
We're glad to see the Canadian gender budgeting act initiative, but the proposed act is just two pages long and the legislation is very general. The reports and the analysis on gender and diversity impacts of the budget of tax expenditures and programs could be so vague and general as to be not particularly meaningful.
I'm also very glad to see legislation for climate action incentive payments to households introduced and the fact that the government is recycling carbon tax revenues in a progressive manner, which is something I've advocated for a decade. I'm very glad to see that. However, there's nothing in the legislation that sets the annual payment amounts or ties them to the revenues raised.
I'm also glad to see the poverty reduction act, but it may be one of the shortest acts ever. I counted up the words. I think there are 51 words. It identifies aspirational targets on poverty reduction, but no definition of poverty. I know the government has a definition of poverty, but it would be good to introduce some of this into the legislation.
At the same time, Bill C-86 includes many amendments to a wide range of taxation and financial industry legislation. These are complicated areas with significant implications and should be accorded adequate time for review.
We appreciate the targeted amendments in part 1 to prevent aggressive international corporate tax avoidance in specific circumstances, but we will also need additional far-reaching measures to reduce aggressive tax avoidance and evasion.
The bill includes 65 pages with amendments to the Bank Act and related acts on financial consumer protection. The issue of protection of financial consumer information is certainly in the news and a reasoned discussion on these issues would certainly be welcome. This section of the bill also includes a provision for the protection of whistle-blowing. One concern is that the definition of “wrongdoing” in this section may be too narrow and just applying to contraventions of the Bank Act and bank policies. There doesn't seem to be any guarantee of follow-up with these reports.
Bill C-86 also includes corrections to previous omnibus budget bills. This indicates to me to a certain extent that pushing through large omnibus bills without sufficient due consideration isn't a wise thing to do, because mistakes can be made.
As you may know, Canada has the weakest corporate transparency regime among the G20 and this makes us a haven for money laundering and tax evasion. I'm glad that this government appreciates the importance of having a registry of individuals with significant control of corporate entities to help prevent money laundering and other criminal activities. However, on pages 134 to 139 of the bill, the amendments to the Canada Business Corporations Act seem too limited and restrictive at this stage. The provisions in this section would result in information that isn't adequate, that could be unreliable because there aren't requirements for verification and may not be timely enough for law investigation and enforcement provisions.
Instead, the legislation should explicitly require corporations to make access available to reporting entities and other parties that require it for regulatory, legal and enforcement purposes—and I believe the committee is going to be reviewing the proceeds of crime legislation, or a report, later. There should be a provision for summary indictable offences and fines, not just criminal convictions. The registry framework also needs to be digital forward to increase efficiency and reduce the costs of compliance. Ultimately, we need a central public registry of beneficial owners for all corporate entities as has been established in the U.K.
In summary, there are a lot of positive and worthwhile initiatives in this bill, but our concern is that a lot has been crammed into one piece of legislation without enough time for reasoned review by the legislature and experts. We'd like to provide some more detailed submissions, maybe, to the committee on specific changes in particular to the Canada Business Corporations Act, if that's possible, later.
Thank you.