Thank you very much, Madam Chair and members of the committee, for inviting me. It's a privilege.
I want to speak about automatic income tax filing, but from a slightly different perspective than usual.
As we know, for most Canadians, filing a tax return is about determining how much money we owe government, but for many low-income Canadians, again as you know, it is about determining how much money the government owes them, and that distinction is crucial.
Over several decades—actually, since 1978—we have constructed an income security system in which filing an income tax return has become the gateway to benefits. People who owe no income tax must nevertheless file a return to receive money intended to help them meet their basic needs. We've made tax filing a condition of receiving benefits, even when there is no tax to pay.
I have four observations over the next four minutes.
The first is in the form of a question: How much does government already know? I've prepared an inventory, which you have, of 43 information items. This is like the normal income tax return that we all do, or that most of us do. It's the simple return that Canadians encounter in navigating the tax and benefit filing process. Not all items apply to everyone, as we know, and some overlap, but many involve information that governments already possess: age, pension income, employment income reported on various T-slips, government benefits and taxes deducted at source. In other words, we frequently require people to tell government what it's already been told, not always to the CRA but to government in general.
Of course, there are circumstances that government cannot know about without asking, but surely we can distinguish between information we genuinely need from individuals and information already sitting in government records. Please look at the 43 items. For people with little income and straightforward circumstances, that distinction should be the starting point for automatic filing.
Second, complexity is not the answer. We're told by some that we have too complex a tax system to bring in automatic filing. C.D. Howe has done that, and they have a point.
Our tax system contains an extraordinary collection of deductions, credits, exemptions and discussion of family circumstances. Not every return can be prepared from the information already available, but I'd like to turn that argument around: If our tax system is too complicated to administer automatically for people whose financial circumstances are simple, perhaps the problem we're looking at is not automatic filing but the tax system itself. The existence of complicated tax returns is no reason to require people with uncomplicated circumstances to complete them.
The third comment is again in the form of a question: What does government really need to know, and when do they need to know it? Governments increasingly expect people to report changes in marital status, address, household composition and other personal circumstances. Some of this information is essential. Marital status can affect benefits and an address is necessary to communicate with people, but we should distinguish three questions: What does government genuinely need to know, when does it need to know it and what should happen when someone fails to report a change on time?
Of course, these are not the same questions. Someone who has moved, separated from a spouse, lost employment or experienced a family crisis may not regard updating government records as their first priority. Government understandably wants accurate information, but that does not justify imposing an unnecessarily continuous reporting obligation on people who may already be struggling. We should examine whether every reporting requirement is necessary. Certainly, the 43 questions on the tax return are not necessary for refundable credits. We should examine whether the timing is proportionate and whether the consequences of non-compliance are fair.
Finally, I'm concerned about the allocation of responsibility for errors. Who is responsible when government gets it wrong? Bill C-31 would allow the CRA to prepare returns for certain eligible individuals who have not filed, and that is a welcome direction, but proposed subsection 150(1.6) also raises a concern about treating errors or omissions as misrepresentations attributable to an individual who fails to correct information on a CRA-prepared return. Think about what that means. Government prepares a return using information available to them. It sends a notice to the individual, who may bear the consequences for failing to identify and correct an error.
There are safeguards and opportunities to respond, but those safeguards must be meaningful for people who need to move frequently, have difficulty receiving mail, struggle with official correspondence or simply don't understand that government may, in some instances, make a mistake. If government takes responsibility for preparing a tax return, it must also accept an appropriate share of responsibility for getting it right.
In closing, I support automatic filing, but its success should not be measured simply by the number of additional returns CRA processes or produces. It should be measured by whether people—