Finance committee  I think it would depend on the facts of the situation, but I think one example would be this: If someone is receiving a car from a third party and they're not paying to use that car, then it would be reasonable to assume that there is some sort of quid pro quo in that situation, some reason why that car is being provided.

Finance committee  I think, again, you would need to look at the situation. We don't expect that there are a lot of situations in which someone receives a car from a third party and does not pay for it and it is unclear as to why they're getting it. I think we're talking about a niche situation here, in which it would be relatively clear that a car is being provided in the course of employment.

Finance committee  It addresses some narrow situations where there have been employers who have engaged.... In an attempt to avoid the current rules, they have had a person who is not related to the employer provide the vehicle to the employee, or they have provided the vehicle to someone who is not related to the employee.

Finance committee  I don't have that information in front of me. I think it's situations that involve car dealerships in particular, where cars are provided to employees and the person providing the car is not the employer and is technically not related to the employer. As a result of a technical deficiency in the rule, that means the amount doesn't get picked up in the employee's income, even though they are clearly getting a car in the course of their employment.

Finance committee  There are some kinds of situations where there was effectively an arrangement between the person's employer and a third party to have the third party provide the car to the employee in an attempt to avoid the rules by having the car be provided by the third party so that the rules don't technically apply.

Finance committee  There's no specific revenue estimate for this measure. I think it's really a clarifying change that is consistent with the policy of the rules as they were initially intended. I think it's not something that's intended to capture a large segment of people. It's addressing a very narrow avoidance situation.

Finance committee  I don't have that exact number in front of me. I think it's expected that not a lot of people would be doing this right now, so it's not expected to impact a lot of people. Basically, a possible loophole exists, so in part, it's being fixed to ensure more people don't try to structure into that type of arrangement to avoid the employee benefit rules.

Finance committee  Clause 2 makes technical amendments to the Income Tax Act related to the standby charge. This is the rule that provides what an employee has to include in their income benefits when they are provided a car by their employer. There are detailed rules that determine how they calculate the benefit.

Finance committee  I can speak to that. The consultation process has been different for different measures. In general, all of the measures in part 1 of the BIA were previously released in draft form for public consultation. In some cases, additional consultation would have occurred earlier in the process.

Finance committee  You're referring to the rules related to Bill C-208? Those rules do not appear in Bill C‑47. In the budget, we published the preliminary legislative provisions that the public can consult. It will be up to the government to make a decision, but it is possible that those rules will be in the bill in the fall.

Finance committee  I can respond to that question. Going back, last summer we released a consultation paper on the GAAR. In this past budget, we released proposed amendments to the GAAR, including draft legislation that included those proposed amendments. Those are out for public consultation until May 31.

Finance committee  All the amendments that were proposed don't contemplate a penalty on promoters or advisers, so there would just be a penalty on the person who has engaged in the tax planning.

Finance committee  Sure. This bill does include changes to create new rules that would require taxpayers, and their advisers and promoters, in certain situations, to report certain aggressive tax planning to the CRA. There are existing rules that exist in the Income Tax Act to address reportable transactions.

Finance committee  None of the measures would support that objective, as far as I'm aware.

Finance committee  Sure. I can try to answer that question. It's a measure that was announced in last year's budget. It addresses certain hedging transactions that financial institutions engage in. Effectively what they do is the following. Under general principles, there's a deduction where a Canadian company receives a dividend from another Canadian company.