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Finance committee  I don't believe we have the information to give you today on the actual amount of dividends on a per country basis. We are trying to get that, and assuming we're able to pull that together we will provide it. I don't believe it's correct to suggest that multiplying the amount o

May 15th, 2007Committee meeting

Brian Ernewein

Finance committee  On the considerations that inform whether we have an exemption or credit system, with an exemption system we end up having a neutrality between us and other foreign competitors in relation to foreign investment. We don't have an additional Canadian tax, current or deferred, that'

May 15th, 2007Committee meeting

Brian Ernewein

Finance committee  I was anticipating the question. Let me speak to it more directly. The assumption or the premise in those sorts of contentions is that the deduction in Canada is a given and the deduction in the foreign country is the gravy. I think that's not immune to challenge. To take our

May 15th, 2007Committee meeting

Brian Ernewein

Finance committee  I believe we did provide a departmental response to the Auditor General in relation to the 1992 and 2002 reports. It does boil down, at its most fundamental, to a policy question for Parliament as to whether we should have an exempt surplus regime where we do or don't impose an a

May 15th, 2007Committee meeting

Brian Ernewein

Finance committee  That's correct, Mr. Chairman. I'm the general director of the tax policy branch in the Department of Finance. I'm joined by my colleague, Lawrence Purdy, who is the senior chief of the tax legislation division in the Department of Finance's tax policy branch. We don't have any

May 15th, 2007Committee meeting

Brian Ernewein

Finance committee  I believe the issue of interest deductibility has been examined on a number of occasions. The Auditor General had occasion to mention it specifically with some detail in 1992 and 2002. The technical committee on business taxation, the so-called Mintz committee, looked into it and

May 15th, 2007Committee meeting

Brian Ernewein

Finance committee  Certainly changes have occurred to the tax system and the economy generally in that time. One change in particular that I would point to is the rather dramatic reduction in our tax rate since that report was issued. I made the comment before a committee hearing on another matter

May 15th, 2007Committee meeting

Brian Ernewein

Finance committee  For this purpose—a low-tax jurisdiction when talking in the context of interest deductibility—what matters is that there's a low-tax jurisdiction with which we have a tax treaty. That's what makes a double dip work.

April 24th, 2007Committee meeting

Brian Ernewein

Finance committee  Its tax rate is lower than ours.

April 24th, 2007Committee meeting

Brian Ernewein

Finance committee  I think the question generally suggests the correct answer. With respect to the U.S. and Japan, and I'd add the U.K., which are probably the three largest countries that have a system whereby on foreign earnings--and we're talking all within the multinational group, not individua

April 24th, 2007Committee meeting

Brian Ernewein

Finance committee  I'd love to give you a single yes or no to that, but the answer is that the change will restrict interest deductions in the future for Canadian companies where they would have been allowed to take an interest deduction in the past. So just viewed in that narrow perspective, it's

April 24th, 2007Committee meeting

Brian Ernewein

Finance committee  Yes. Where it places Canada vis-à-vis other countries, such as the U.S., the U.K., and Japan, will depend on what happens. If the money is being brought home and there's more money being earned by the foreign affiliate than the interest expense associated with it, our regime is

April 24th, 2007Committee meeting

Brian Ernewein

Finance committee  I believe that's right, and to reference Mr. Carney's remarks, on the whole there have been some very dramatic changes trying to make Canada's system overall more competitive. Our corporate tax rates at the beginning of this millennium were 50% higher than they'll be a decade aft

April 24th, 2007Committee meeting

Brian Ernewein

Finance committee  I apologize for answering a question with a question, but it seems to me, following Mr. Carney's remarks, that as far as a sales tax or consumption tax in Canada is concerned, we have neutrality in the system today. Whether a good is produced in Canada or produced in China, when

April 24th, 2007Committee meeting

Brian Ernewein

Finance committee  I believe the considerations mentioned by Mr. Poschmann are relevant. It has also been noted that real estate investment trusts have largely obtained recognition internationally. The government of the day made changes explicitly for the purpose of facilitating real estate investm

February 13th, 2007Committee meeting

Brian Ernewein