Finance committee  No, thank you. Actually, that's perfect. It's my understanding as well that the effect of the measure would be to eliminate a requirement currently in the rules, which would naturally tend to increase amounts drawn from the CRF, consolidated revenue fund. That would be tantamount to additional government spending.

Finance committee  Thank you for the question. There are of course no amendments to the general anti-avoidance rule in Bill C-19. I just wanted to make that clear. The government did announce a specific amendment to the general anti-avoidance rule in budget 2022 that would extend the definition of “tax benefit” to apply to tax attributes, which would allow the creation of tax attributes to be challenged closer to the time the initial transaction is put in place, which provides certainty earlier on in the process.

Finance committee  Thank you for the follow-up question. Yes, of course, the department is very much involved in studying and analyzing the impacts of the Alta case. Recently, through an act of Parliament, Canada enacted the multilateral instrument, which is a rule developed with a number of other international partners to help address some of the issues that came to the fore in the Alta decision, to which I understand was being referred.

Finance committee  I believe it would be up to the government ministers to table bills.

Finance committee  As I noted earlier, I think my response would be the same to this question. It is a decision for the government as to what measures get included in the bill. It's fairly normal procedure for some of the more complex measures, or measures that might benefit from more stakeholder engagement, to have that additional stakeholder engagement done after the tabling of the first budget bill through the summer.

Finance committee  That is correct. The 2022 federal budget announced a measure relating to carbon capture and storage. It is also entirely correct that it's not contained in the first budget implementation bill. I can say that, for a lot of more complicated measures, as the CCUS credit would be, it is normal for the government to delay their implementation or inclusion in a bill until, for example, the second budget implementation bill that is often tabled in the fall, in order to receive stakeholder feedback and consult with affected stakeholders.

Finance committee  As I noted, the measure's not contained in Bill C-19. It will ultimately be a decision for the government as to what legislative vehicle the measure would be included in. As I said, it's fairly normal course for some of the more complicated measures to be announced in a budget. Quite often draft legislative proposals are released in the summer for further consultation, and then the measures can be included in a fall budget bill.

Finance committee  Thank you, Chair. I'm of course here to provide technical analysis. I'm happy to help out within the scope of what is appropriate, and I will defer to the chair's judgment on the scope of that. If it would be appropriate for me to answer the question, I could provide some insight or some thoughts, but again, as Mrs.

Finance committee  Thank you for the question. I think I would direct a question to the chair, or perhaps the parliamentary secretary. I just want to be sure about my role in appearing before this committee. My understanding was that it is to provide technical advice on the contents of the bill and the amendments.

Finance committee  I can provide a short answer, which is that the Canada Revenue Agency has been developing guidance on rules. With any amendment in the bill, they would continue to do so, so that taxpayers are apprised of their rights and obligations through the bills that are enacted by Parliament.

Finance committee  That's absolutely correct. Of course, I would not speak on behalf of the Canada Revenue Agency about their IT and system requirements. I know they've been working tirelessly on implementing the systems required to get the mechanisms under the bill. If it would be helpful to clarify things, I always find it's best to think of concrete examples.

Finance committee  As I noted, I'm not certain whether or not the Canada Revenue Agency.... I'm not certain what kinds of delays in the delivery of the programs this would lead to with the CRA systems. I'm sorry. I don't know that.

Finance committee  Maybe I'll start with your second question first. As noted, there's a concern that because the rules apply to all dividends and not just dividends paid on the publicly listed shares, they could require repayment of the wage subsidy where one entity in a corporate group is moving funds to another entity in the corporate group for the group's purposes and not actually returning any amounts to shareholders.

Finance committee  Thank you for the question. I can start with the second part, perhaps, and then turn it over to my colleague Max Baylor. He can speak to the number of public companies that would be affected. As I understand the question, it was to provide a brief overview of some of the technical issues with the amendment that have been identified.

Finance committee  Okay. Thank you very much. As was already noted, the coming-into-force rule would have made it retroactive. With no coming-into-force rule, the default rule would be that it comes into force on royal assent. That would lead to some ambiguity, still, in terms of when it would apply.