Finance committee  I think there will be other people here at a later time on part 4.

Finance committee  Yes, that's right. We're just from the tax policy branch, so I don't think we have those numbers handy. We could get them for you.

Finance committee  Thank you, Mr. Chair. I'm Lindsay Gwyer, director general, legislation, at the Department of Finance. I'll be speaking about part 1 of the bill. Part 1 contains the income tax measures. There are 15 measures in part 1 of the bill, in addition to a number of technical amendments.

Finance committee  They're in proposed subsection 124.46(16) on page 173.

Finance committee  I don't have the information in front of me. It would relate to any insurance companies, so it would exempt the insurance companies broadly.

Finance committee  It would exempt any dividends received by an insurance company in respect of a share that's held by the corporation in the ordinary course of its insurance company business, as well as if the share is received through a mutual fund trust.

Finance committee  If they're holding the share in connection with their insurance business, yes.

Finance committee  It's a benefit that would, generally speaking, be conferred on the insurance company, but what we have heard from some insurance companies is that that cost would be passed on to policyholders if the amendment was not made. Directly speaking, under the existing rules for financial institutions, a dividend received deduction would be denied, including for insurance companies, and this would provide an exemption so that insurance companies, if they meet the conditions of this exemption, would be able to continue to claim the dividend received deduction.

Finance committee  I think it's a policy decision and a political decision whether to provide an exemption for financial institutions more broadly or just for insurance companies. I think one of the concerns is that the insurance companies, in particular, have pointed to a number of products for which they have suggested that fees will be passed on to customers.

Finance committee  I will respond to that. To ensure that my answer is clear, I'll respond in English. With regard to the first question, yes, it is common to announce changes that are tightening, for them to apply on a perspective basis and for that to be before the legislation is ultimately introduced into Parliament and receives royal assent.

Finance committee  I'll speak about the EIFEL amendments specifically. It was first announced in budget 2021. The detailed legislation was first published at the beginning of 2022. It is common for changes, especially tightening changes, to be announced and then made prospective from when they are announced.

Finance committee  Yes, the revenue has been booked for the rules. I would have to find.... It would be what was in the budget.

Finance committee  Yes. If there was an amendment that would effectively make the rules narrower, it would have costing implications, and, yes, that would require a change to the revenues that have been booked.

Finance committee  Yes.

Finance committee  Yes, the rules apply generally to taxes beginning on or after October 1, 2023. A wide number of clauses in here deal with EIFEL rules, and at the end of each clause there's the coming-into-force provision. The main clause that deals with EIFEL rules, or one of the larger ones, is clause 7, so at the end of clause 7 there's a coming-into-force rule, but again, throughout the bill there are a number of EIFEL amendments, and each has to have its own coming-into-force rule.