Finance committee  It's not quite accurate to say that prohibited investments, over-contributions, and non-qualified investments were not contemplated. If you look at the act as it sits right now, before the amendments proposed here, you will find that all of those concepts are represented in the a

Finance committee  You're looking into some older history, and that's why Mr. Wach is not responding, but I was at the department at the time when that was being developed. It was a difficult balance to be presented. We had some existing registered plans, for example, the RRSP, the RDSP--register

Finance committee  The department developed the parameters of the program in conjunction with the minister's office, and the result was what was included in the bill and approved by Parliament. Was there a proper review all the way through? Yes. It was reviewed by the department, it was reviewed in

Finance committee  The process for drafting legislation within the Department of Finance is one that involves several levels of review and checks and balances, up to and including my level. And of course that needs to be signed off by the minister before it's recommended to Parliament and included

Finance committee  There are some wrinkles with respect to taxpayers who have already instituted a case and had a decision from the tax board. In fact, we're aware of only one. We're looking at that. With respect to retroactivity, generally, if somebody hasn't appealed yet, then it should be okay.

Finance committee  Well, the policy recognizes that it is within the domain of the other jurisdiction to tax corporations that carry on business inside their borders in the same way that it is up to Canada to impose taxation or not on subsidiaries of foreign parent companies that are resident in an

Finance committee  The department, of course, wouldn't be in a position to make such a change. Parliament has to do that, so we'll prepare the legislation for the minister and it's up to the minister to include it in a bill.

Finance committee  That type of legislation ought not to take that long to do, but within the parliamentary process and when the minister decides to introduce that bill, that's within ministerial responsibilities.

Finance committee  First, we don't look at every appeal that comes through. The Income Tax Act does have a series of provisions that govern when taxpayers can appeal their tax assessments and when no appeal is allowed. In general, no appeal is allowed in circumstances where there's no tax in dispu

Finance committee  In fact, there are a number of cases where there are exceptions to the basic rule where you can't appeal. An example that comes to mind is a determination of a loss carried forward, where a taxpayer may want to know for certainty now the determination of a loss for any given taxa

Finance committee  Your question stems in large part from Canada's historical position on tax treaties and how Canada taxes the income of foreign affiliates of Canadian corporations that carry on active businesses in foreign countries. I started with the department in 1982, so for at least some 2

Finance committee  It is for the chair of this committee to say whether I have to answer that question or not. I have no problem doing so, but it may be for the chair to say one way or the other.

Finance committee  I will wait for the answer of the....

Finance committee  I don't think it's a matter or a question of the willingness of the bureaucracy. We make recommendations, of course, to our political masters, but the minister has already indicated to the committee that the situation is wrong and needs to be fixed, and he's directed us to ensure

Finance committee  It would be up to the Department of Finance to do it, that's correct.