Evidence of meeting #59 for Finance in the 42nd Parliament, 1st Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was physicians.

A video is available from Parliament.

On the agenda

MPs speaking

Also speaking

June Dewetering  Analyst
Clerk of the Committee  Ms. Suzie Cadieux
John Lawford  Executive Director and General Counsel, Public Interest Advocacy Centre
Terry Campbell  President and Chief Executive Officer, Canadian Bankers Association
Brigitte Goulard  Deputy Commissionner, Financial Consumer Agency of Canada
Scott Chamberlain  Director of Labour Relations, General Counsel, Association of Canadian Financial Officers
Fabiano A.S. Taucer  Head of Diagnostic Imaging, Montfort Hospital, Ontario Association of Radiologists
Ray Foley  Executive Director, Ontario Association of Radiologists
Jacques St-Amant  Consultant, Public Interest Advocacy Centre
Aaron Wudrick  Federal Director, Canadian Taxpayers Federation
Marshall Schnapp  Ombudsman, ADR Chambers Banking Ombuds Office
Angella MacEwen  Senior Economist, Canadian Labour Congress
John Feeley  Vice-President, Member Relevance, Canadian Medical Association
Laura Tamblyn Watts  Senior Fellow and Staff Lawyer, Canadian Centre for Elder Law
Richard Davies  Professor, Division of Cardiology, University of Ottawa Heart Institute, Canadian Medical Association

3:35 p.m.


The Chair Liberal Wayne Easter

We'll call the meeting to order. Pursuant to the order of reference of Tuesday, November 15, 2016, we are studying Bill C-29, a second act to implement certain provisions of the budget tabled in Parliament on March 22, 2016, and other measures.

We have many witnesses to go through. All witnesses are related to their concerns about or praise for Bill C-29.

Mr. Liepert, you had a point you wanted to raise.

3:35 p.m.


Ron Liepert Conservative Calgary Signal Hill, AB

Before we start, I just want to ask the folks from the library whether we're still on track to get our pre-budget consultation report at the end of this week.

3:35 p.m.

June Dewetering Analyst

We believe so. Suzie has been more recently in contact with them, so she may want to add something.

3:35 p.m.


The Chair Liberal Wayne Easter

Do you think we're on track?

3:35 p.m.

The Clerk of the Committee Ms. Suzie Cadieux

Yes, we are.

3:35 p.m.


The Chair Liberal Wayne Easter

We believe we are on track, and that would mean we would have it at the end of business on Friday. Yes, there will be lots of reading.

Before I turn to the witnesses who are here, I want to mention that Michael Veall from the department of economics, McMaster University, wasn't able to come. He had intended to come. His presentation, for members' benefit, is on your iPads.

We'll start, then, with the first witnesses. We ask witnesses to hold their remarks to about five minutes, and then we will go to a series of questions.

We'll start with the Public Interest Advocacy Centre, Mr. Lawford and Mr. St-Amant.

3:35 p.m.

John Lawford Executive Director and General Counsel, Public Interest Advocacy Centre

Thank you, Mr. Chair.

Honourable members, my name is John Lawford, and I am executive director and general counsel at the Public Interest Advocacy Centre, on behalf of which I am appearing today. With me is Jacques St-Amant, who teaches consumer law at the Université du Québec à Montréal and acts as a consultant to PIAC regarding financial services.

We're focusing today exclusively on division 5, part 4 of the bill. Our main message is that the bill's financial consumer protection framework will not improve the protection of banks' customers and may, in fact, make things worse.

In his 2013 budget, the then Minister of Finance announced the government's intention “to develop a comprehensive financial consumer code to better protect consumers of financial products”. This was followed by further announcements on this topic in every single budget, including the 2016 budget, which promised “a comprehensive, consolidated framework and include targeted and more flexible consumer protection rules to better respond to Canadians’ changing needs.”

We were cautiously hopeful that needed change was coming.

The current rules are deeply unsatisfactory. The FCAC—or Financial Consumer Agency of Canada—website lists over 50 provisions of the Bank Act, 28 regulations under the act, six voluntary codes of conduct, and over a half a dozen public commitments claiming to protect consumers. Very few consumers know these rules or understand what they mean. Many of them are not strong enough and they are not legally enforceable by a consumer. Often there is no rule, beyond a general legal principle to protect the consumer.

What Bill C-29 does is moves around the existing rules between the act and regulations, making the framework more rigid at a time when swift market evolution would require a more flexible set of rules. It does add five new principles, the legal impact of which is unclear, and some small changes regarding other issues, but it adds provisions that are clearly also unhelpful to consumers.

Bill C-29 does not address the real problems, such as banks unilaterally changing provisions in their terms and conditions, or disclaiming in their terms and conditions any liability for mistakes or negligence. As an example, we provide in the annex to these remarks a provision from CIBC's current terms and conditions. There is nothing in the Bank Act, or in Bill C-29, that prohibits such provisions. Contrast that with the consumer protection code established by the Central Bank of Ireland, which requires banks to act with skill, care, and diligence in the best interests of their consumers, and which prohibits, in principle, exclusionary clauses, such as I referred to.

Complaint resolution is not addressed by BillC-29, even though the current regime allows a bank to choose its external ombudsman—an obvious conflict of interest. FCAC remains the watchdog under Bill C-29. However, it was given very limited powers in 2001, which have not been significantly increased over time, simply compared with the U.S.'s Consumer Financial Protection Bureau.

This is a weak framework. It is full of gaps. We are therefore worried by Bill C-29's apparent attempt to confine the protection of banks' consumers to this regime, as we understand that the intent behind proposed new section 627.03 is to thwart the application of provincial consumer protection legislation in banking. This is not a good idea.

First, consumers of banks would then be less well protected in some provinces than if they did business with, say, a local credit union, which would be subject to provincial rules. In effect, Parliament would be creating a disincentive for consumers to do business with banks.

Second, consumers of all provinces may not be treated equally. It is settled law that federal legislation is not paramount to common law, so the absence of any provision regarding unfair transactions in the Bank Act may have no impact on, say, the application of common law unconscionability rules in nine provinces. In Quebec, where similar rules are legislated in the provincial civil code and the Consumer Protection Act, those provincial laws could be found to be inoperative under this constitutional theory propounded in the bill. More simply stated, Bill C-29 invites constitutional wrangling instead of promoting legal certainty, which will harm consumers and banks.

However, we have an even more fundamental issue with what the minister proposes. In effect, he is inviting Parliament to declare that in Canada the convenience of bankers is more important than the protection of consumers. We believe that is mistaken and will not be popular.

Financial service consumers would gain by the implementation of a strong, coherent, and comprehensive set of legally enforceable rules that would be consistent with the Canadian constitutional framework established through an open consultative process. This set of federal rules could act as a floor, and if the floor were built high enough, provinces likely would not feel the need to offer additional protection to their residents, which would further the goal of consistency. This is not, however, what Bill C-29 currently does.

In conclusion, we suggest that this committee recommend to the minister that he take stock of these issues, withdraw the division from the bill, and consult again in order to implement, in the context of the upcoming global review of the Bank Act, a truly effective financial consumer protection regime.

Thank you.

3:40 p.m.


The Chair Liberal Wayne Easter

Thank you very much, Mr. Lawford.

For the Canadian Bankers Association, we'll hear Mr. Campbell and Ms. Cotroneo.

3:40 p.m.

Terry Campbell President and Chief Executive Officer, Canadian Bankers Association

Thank you, Mr. Chair. Good afternoon, ladies and gentlemen.

We would like to thank the committee for inviting the Canadian Bankers Association to participate in the committees review of Bill C-29.

The CBA works on behalf of 59 domestic banks, foreign bank subsidiaries and foreign bank branches operating in Canada and their 280,000 employees.

Our opening remarks will address the provisions contained in division 5 of part 4 of the bill. These amendments to the Bank Act consolidate and streamline the consumer protection provisions that apply to banks under a federal financial consumer protection framework. My introductory comments are going to focus on the broader aspects of the amendments that will affect the banking industry and our customers.

Building and maintaining a strong client relationship is of fundamental importance to Canada's banks. Banks are an active and essential part of the daily lives of Canadians. Ninety-nine per cent of Canadians have an account with a financial institution, so many millions of Canadians turn to banks every day for products, services, and financial advice. We help Canadians safeguard their money, finance a home, manage their savings, plan their investments, and prepare for retirement.

Banks in Canada take very seriously their role in the lives of individual Canadians, and Canadians trust their banks and value the products and services they provide. In fact, Canada's banks have been recognized internationally for their commitment to providing a good consumer experience. Our banks have been ranked first out of 32 countries in the Capgemini “World Retail Banking Report” every year since 2012.

Bill C-29 consolidates the consumer protection provisions that exist in federal legislation as they have evolved over many years, including new measures, into a single financial consumer protection framework within the Bank Act. By creating a clear federal framework, Bill C-29 ensures that Canadian customers continue to benefit from consistent, safe, and high-quality banking products and services across the country.

Consolidating consumer protection and establishing a uniform set of standards under a single framework will improve the efficiency of financial services regulation, ensure consistent policy across the country, prevent consumer confusion, maximize product availability, and ensure the capacity of the Financial Consumer Agency of Canada to fulfill its regulatory mandate to inform and protect consumers.

We support the placing of the consumer protection framework under the oversight of a single regulator. The FCAC was created in 2001 to strengthen oversight of consumer regulation and expand consumer education. The industry has a long-standing and strong working relationship with the FCAC in many areas, particularly in the area of financial literacy.

We also support a framework of consumer protection principles that are not prescriptive and that can be adapted to change. Allowing and encouraging further innovation in the financial sector is essential, so that banks can continue to serve the needs of consumers by developing and enhancing financial products and services and the way they are delivered to our customers.

As leaders in financial technology, banks in Canada are constantly innovating, developing new products and services to meet the demands of their customers for greater convenience. Canadians can now bank at any time, from virtually anywhere, through online and/or mobile banking. Every year, more and more Canadians are adopting online and mobile as their preferred means of banking. Despite this trend, however, banks have maintained an extensive branch network across the country, because that is where relationships with their clients are often established and maintained.

More clarity about the implementation of the framework is going to be provided through the development of subsequent regulations, and we look forward to engaging in that process. Our aim would be to achieve a workable, efficient, and flexible approach for the benefit of Canadian consumers.

With the start of the global financial crisis now nearly a decade behind us, it's important to keep in mind that Canada's prudently managed banks, combined with an effective financial services regulatory and supervisory framework, were key reasons for the strength and the resilience of Canada's banking system. A key lesson of that crisis was the importance of a streamlined, coherent, and unified regulatory system, which we have in Canada, with a single regulator responsible for safety and soundness—the Office of the Superintendent of Financial Institutions—and a single regulator for consumer protection, the FCAC.

The CBA and its members have long supported a strong federal regulatory framework for the benefit of consumers. Although Canadians already benefit from a strong protection system, we think the federal framework proposed in Bill C-29 is an important step in the direction of further improving that regime, with a clear, streamlined, and consistent set of regulations that are applied across the country.

Thank you again for inviting us to be here today, and we look forward to your questions.

Thank you.

3:45 p.m.


The Chair Liberal Wayne Easter

Thank you very much, Terry.

We turn to the Financial Consumer Agency of Canada, Ms. Goulard and Mr. Bilodeau.

Go ahead, Ms. Goulard.

3:45 p.m.

Brigitte Goulard Deputy Commissionner, Financial Consumer Agency of Canada

Good afternoon, and happy financial literacy month.

My name is Brigitte Goulard. I am the deputy commissioner of the Financial Consumer Agency of Canada, and my colleague Richard Bilodeau is the director of our supervision and promotion branch.

Thank you for the invitation. I look forward to providing you with our comments on Bill C-29.

The Financial Consumer Agency of Canada, or FCAC, is a federal government agency responsible for protecting consumers of financial products and services. The agency supervises the practices of banks, federal credit unions, and trust and loan companies. It also develops resources and organizes activities to strengthen the financial literacy of Canadian consumers. Lastly, the agency is mandated to monitor and evaluate trends and emerging issues that may have an impact on consumers of financial products and services.

We monitor external complaints bodies, or ombudsmen, if you will. Every bank and federal credit union must be a member of one of the two approved external complaints bodies.

Consumers who feel that their financial institutions haven't adequately handled a complaint about some banking activities can contact one of these bodies. The representative of one of the two approved bodies, namely, ADR Chambers—Banking Ombuds Office, also appeared before you today.

We also ensure that credit and debit card networks comply with certain business practice requirements to protect merchants. These networks include VISA, MasterCard, American Express and Interac.

FCAC welcomes the new financial consumer protection framework included in Bill C-29. If adopted, it will better protect financial consumers.

We are particularly pleased with the introduction of guiding principles that set out expectations to guide banks' conduct, and will help FCAC interpret and then enforce the legislation. Other enhanced consumer protection measures include improving access to basic banking services by allowing the use of a broader range of personal identification documents to open an account or to cash government cheques.

It also includes strengthening business practices' oversight by introducing a new prohibition on applying undue pressure and by adding cancellation periods to a wider range of products and services. It enhances disclosure of key information by expanding the use of summary boxes of information to all banking products and services. It also enhances transparency by requiring banks and external complaint bodies to report on the nature of complaints received. Finally, it will improve accountability by requiring the banks to report on how they are addressing the principles of the consumer framework and the challenges faced by vulnerable Canadians.

In anticipation of this new consumer framework, FCAC has spent the last year revising its own supervisory framework. I am pleased to announce that our new supervisory framework will be launched in spring 2017.

Three pillars underpin our new supervisory approach. The first pillar focuses on promotion, as FCAC believes that compliance is facilitated when obligations are clearly identified and accessible to regulated entities. Second, FCAC proactively monitors regulated entities to determine whether they are complying with their obligations. FCAC also gathers information on current and emerging issues that impact financial consumers. Finally, FCAC enforces the financial institutions' market conduct obligations. When a potential breach of a compliance obligation is identified, we investigate and take the appropriate action to respond to non-compliance and to deter any further non-compliance.

With this new supervisory framework, we will proactively identify issues in the marketplace and take a more risk-based approach in our supervision and enforcement activities. We believe this approach will better position us to implement the legislative changes proposed in Bill C-29.

To ensure the adoption of the new framework for consumers, FCAC will work closely with stakeholders, including consumers, federally regulated financial institutions and regulators in the provinces and territories. This collaborative approach is at the heart of FCAC's activities and guides all of its activities.

Thank you again for allowing me to meet with you. My colleague and I will be happy to answer your questions.

3:50 p.m.


The Chair Liberal Wayne Easter

Thank you very much.

I'll maybe give an explanation because it's quite unusual for us to have this many people on a panel. When we first looked at this panel and the deadline we're under on Bill C-29, we thought there might be votes today. Usually when there are votes, we end up cutting the last panel short.

I encourage members to take notes. We will go two rounds of questions, five minutes all the way around because I know there are a lot of panellists. Not everybody has to use their five minutes twice. It is so that people will not be rushed and can get enough questions in.

From the Association of Canadian Financial Officers, Mr. Chamberlain, go ahead.

3:50 p.m.

Scott Chamberlain Director of Labour Relations, General Counsel, Association of Canadian Financial Officers

Thank you.

Honourable members, thank you for the opportunity to appear today. The Association of Canadian Financial Officers represents the operational core of the federal government's financial workforce.

We understand how important public revenue is to delivering vital public services to Canadians and that fiscal responsibility requires both prudent spending and fair tax collection. We believe the best way to serve Canadians is through responsibly funded public services delivered by a professional and modern public service.

We believe that our leaders must first ensure that all Canadians contribute their fair share before resorting to austerity measures and the sale of valuable public assets. We recognize that progress in this regard is being made by this Parliament. You are delivering and engaged in a mission to modernize the tax regime. Millions have been invested in efforts against tax havens, and there has been a corresponding increase in recovered revenue, investigations, and audits.

We are encouraged by the government's ongoing review of tax expenditures with the purpose of further simplifying and rendering fair taxation in Canada. ACFO supports these efforts and we support Bill C-29, which includes provisions that contribute to this work.

Today we offer suggestions only on what further provisions could be implemented to maximize the effectiveness of this new regime. I'll start with the OECD BEPS initiative. In budget 2016, the government committed to working with the OECD and its action plan on tax avoidance. The OECD BEPS initiative represents an unprecedented international effort to modernize international tax and to ensure fair and stable government funding globally.

Bill C-29 helps establish the cornerstones of OECD BEPS by implementing both the country-by-country reporting standards and the common reporting standard for the automatic exchange of information between tax authorities. These are crucial steps towards a comprehensive global strategy against tax evasion. The country-by-country reporting framework, however, will require further improvements if it is to function optimally. Specifically, many developing countries, including many tax havens, lack the capacity to participate in the OECD BEPS framework, and the vast majority of multinational entities will not be required to report under the current thresholds.

Canada should seize the opportunity to lead on tax globally by spearheading the following: supporting developing nations' efforts to build capacity in order to participate in the OECD BEPS framework; calling for the establishment of a UN international tax body to complement the efforts of the G20 and the OECD and broaden the base of participation; calling for the lowering of the country-by-country reporting thresholds, which currently would not apply to 90% of the multinational entities; and finally, calling for most information in the country-by-country reports to be publicly available.

The details and full rationale of these recommendations can be found in ACFO's recent white paper, “Tax fairness: An opportunity to lead”, copies of which have been provided through the clerk today.

In addition to leading on OECD BEPS, Parliament could continue to focus on complementary domestic measures, including implementing this committee's October 2016 report, “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions”. The recommendations therein serve as a practical and reasoned road map for building on the progress made thus far. As someone who appeared at that committee, I thank the members for the good work on that report. We fully support it.

Other complementary domestic measures that Parliament could focus on include establishing a national public beneficial ownership registry, and finally, continuing in efforts to eliminate tax expenditures, which in our opinion should include the stock option deduction, which costs $100 billion annually, encourages speculative behaviours, and overwhelmingly benefits the top one per cent with largely no discernible economic benefit, save and except for a reasonable exception for the high-risk innovative tech sector, for which there could be a reasonable cap.

In conclusion, as proud, hard-working public servants, ACFO's members help deliver on this government's agenda of infrastructure investment, reconciliation with our indigenous people, pay equity, growing the middle class, and supporting sustainable economic growth. Bill C-29 helps establish a stronger and fairer tax regime that we can build on for securing the revenue needed to achieve these goals for Canadians without resorting to further austerity measures and privatization.

Thank you.

3:55 p.m.


The Chair Liberal Wayne Easter

Thank you very much, Mr. Chamberlain.

Next is the Ontario Association of Radiologists, Mr. Foley and Mr. Taucer.

3:55 p.m.

Dr. Fabiano A.S. Taucer Head of Diagnostic Imaging, Montfort Hospital, Ontario Association of Radiologists

Thank you, Mr. Chair, and ladies and gentlemen. Thank you for the opportunity to present to this committee.

My name is Fabiano Taucer. I'm here with Ray Foley, the executive director of the OAR. I've been a practising physician in Ontario for 37 years, and for the past 28 years here in Ottawa at the Montfort Hospital as a radiologist and nuclear medicine physician.

In a nutshell, there are three issues I want to touch on regarding the small business deduction as it pertains to physician groups. The first is how medical practice has evolved, requiring the creation of group practices to the benefit of patient care; two, how the proposed legislation would lead to a dissolution of these group practices resulting in significant, unintended consequences negatively impacting patient care; and three, how and why physician groups should be exempted from the proposed legislation.

We're all aware of the ever-increasing complexity of medicine and medical knowledge. Hardly a week goes by that we don't see an item in the newspaper or in the media about some new therapy, some new surgical procedure. Some of you may have seen on the CBC television news last night an item where a neurosurgeon in Winnipeg used a new therapy on a young woman with a brain tumour by inserting a probe into the brain while she was conscious and treating that tumour.

This increasing complexity has led to the development of not just specialists, but subspecialists and super-subspecialists. The delivery of this type of subspecialty care is fostered and supported within group practices. The provision of 24-7 care from family physicians to specialists and subspecialists is likewise supported within the framework of a group practice.

In my own field of diagnostic imaging, groups have evolved to provide a full gamut of care, not just the direct doctor-to-patient care but many other things that occur in the background that have a direct and indirect effect on patient care. We're able to provide these key services, many of which are not remunerated or poorly remunerated, within the setting of a group practice, such as teaching, research, administration, quality control, leadership, as well as certain clinical services; yet all of these services impact directly or indirectly on patient care.

Pooling of income within a group model allows the best teacher in each subspecialty area to teach, the best administrator to advise the hospital or institution, the best clinician in her field to practise in that area, the best researcher, and so on. This can take place without a financial penalty to the individuals involved. I'm sure you can see how all of this benefits patient care both in the short and in the long term.

The removal of the small business deduction would have the opposite effect and would be a disincentive to provide non-remunerative yet important work.

Physician partnerships are different from other professional partnerships with respect to this legislation in two important ways. First, they operate in a not-for-profit system with no control over the fees that are set by provincial governments. Secondly, there is no multiplication of the small business deduction in physician groups, such as may have occurred with other professional groups.

My premise is simple. The legislation, as proposed, would have serious short- and long-term negative effects on patient care in this country, and I'm sure that was not the intent of the legislation.

4 p.m.

Ray Foley Executive Director, Ontario Association of Radiologists

We have some recommendations in terms of that same goal. First, we're seeking that the legislation be amended to carve out publicly funded health care delivered by medical practitioners who deliver their services in professional medicine corporations, which are a readily identified activity by CRA.

Second, we seek amendment in the legislation to recognize that policy objectives aimed at for-profit partnerships, whether they be legal, accounting, or otherwise, are not applicable to not-for-profit delivery of health care services as we know them under the Canada Health Act, following the litmus test of medically necessary examinations.

The third would be that a decision on this matter be made quickly. We have a thousand radiologists in Ontario, 2,800 across Canada. In the case of the thousand physicians in Ontario, they service 13 million patients. The lack of a decision is causing people to make decisions, and when enjoined with some of the other turbulent activities happening in the public sector at a provincial level, this creates unnecessary and dangerous instability.

The concern is that physicians, not just radiologists but physicians generally, will do what happened in the 1980s, 1990s, and the early 2000s, and that is that they will move to other jurisdictions, principally the U.S., to provide services. That, obviously, is one of the unintended consequences that we see, which obviously tax planners or policy-makers did not have in mind when they set out to do this, in terms of what the implication is for both federal and provincial health policy across the country.

The fourth is that if there is a change in the tax legislation that it be communicated as effectively and as efficiently as possible, that it be done through bodies like our own or the Canadian Medical Association in order to address this significant undercurrent that remains in the minds of practising doctors across the country.

Thank you.

4:05 p.m.


The Chair Liberal Wayne Easter

Thank you all very much for your presentations.

We turn to the first round of questions with Mr. Sorbara.

4:05 p.m.


Francesco Sorbara Liberal Vaughan—Woodbridge, ON

Thank you, Mr. Chair. Welcome, everyone.

I do wish to acknowledge two young folks from my riding who are here in the committee, paying attention. They are sitting in the back. Welcome, Stefano and Cassandra. It's great that you can spend the day with the MP.

Now I'll go on to the questions. I'll divide my time up and I'll group it into the Canadian Bankers Association, along with Mr. Lawford and Mr. St-Amant, and then I'll move over to the radiologists.

Mr. Campbell, with regard to your comments on the Canadian Bankers Association, I'm generally in line with your view of it. We've always maintained a strong regulatory framework and it has always been a balance between provincial jurisdiction and federal jurisdiction with regard to the banks in Canada, more so on the federal side.

One of the reasons we came out of the financial crisis so strong, I believe, is that we had a lot of good regulatory oversight from the federal side, be it OSFI or other regulatory institutions. I wonder if you can elaborate on the comment on the streamlined, clear, and consistent set of regulations that you mentioned.

4:05 p.m.

President and Chief Executive Officer, Canadian Bankers Association

Terry Campbell

Sure. Thank you very much. I appreciate those comments.

Again, I go back to the financial crisis. If we looked at many other jurisdictions in the world, certainly south of the border, we saw a multiplicity of regulators often working at cross-purposes. We didn't have that here.

I do agree with you that strong regulation and strong supervision through a unified regulator was part of the recipe of why Canada was able to get through the crisis with its head held high, and it served as a model. I see the bill, quite frankly, in front of us as carrying on that tradition.

Our sense is that what is important for the consumer is a consistent, clear, and coherent set of rules that is under a uniform system of supervision. It doesn't help consumers at all to have duplication or conflict or confusion as to whom to turn to in cases of concern.

Now, the devil is in the details and we haven't seen all the regulations yet, but what Bill C-29 does, from our perspective, is provide that clarity of intent, provide uniform consumer protection and uniform supervision. We think this is the strongest system. It already has a high-quality set of rules, which are higher, actually, in terms of some of the changes and enhancements and new provisions put in. We think this will be good for consumers.

4:05 p.m.


Francesco Sorbara Liberal Vaughan—Woodbridge, ON

Thank you, sir.

I'll move over to the radiologists. There was one interesting comment in your presentation that within the group structure there is no multiplication of the small business deduction. Can you elaborate on that? Obviously, we have heard, and I have heard, from a number of physicians and physicians' groups across the country in the last number of weeks and in the last few days, so I do understand your concerns.

However, I wanted to zero in on this comment that you made about there being no multiplication to the small business tax deduction.

4:10 p.m.

Head of Diagnostic Imaging, Montfort Hospital, Ontario Association of Radiologists

Dr. Fabiano A.S. Taucer

Thank you for the question and picking out the one thing that doesn't have to do with medicine.

4:10 p.m.


Oh, oh!

4:10 p.m.


Francesco Sorbara Liberal Vaughan—Woodbridge, ON

I'm not a doctor.

4:10 p.m.

Head of Diagnostic Imaging, Montfort Hospital, Ontario Association of Radiologists

Dr. Fabiano A.S. Taucer

I would describe it this way. In the current setting, in our group we have 12 radiologists. Each of those 12 radiologists is entitled to take advantage of the small business deduction, and there's not an additional deduction for each of those radiologists. Should the legislation go through, the partnership would be dissolved and each of those 12 radiologists would be allowed to take advantage of the small business deduction.

That doesn't directly answer your question, but my understanding of multiplication is that there are certain partnership structures that allow for individuals to effectively take advantage of that low tax rate for small business multiple times, rather than just one for that individual.

4:10 p.m.


Francesco Sorbara Liberal Vaughan—Woodbridge, ON

That is the way I understand it as well.

We know the delivery of health care is more a provincial area of responsibility. Obviously, there is the Canada health transfer and a lot of other stuff, but in terms of delivery and your comments on speciality and subspecialty care within the group practices, can you elaborate on that, please? I am worried about the unintended consequences of changes.