Finance committee  Or they would be subject to a SIFT tax. The expectation was that most of those SIFTs would convert rather than be subject to the SIFT tax. What we found, in terms of converting, was that the SIFT trusts and partnerships were looking for loss corporations to amalgamate with rathe

Finance committee  Again, I'll pass that to my colleague Ed Short, who's got carriage of that particular file. One thing I will note, and Ed can correct me if I'm wrong, is that because this requires an actual reporting requirement, the CRA isn't able to require the reporting by taxpayers until th

Finance committee  In terms of the income tax side, I think what you're talking about are the new measures where there has not been a consultation as yet, prior to introducing the bill. There are three areas where there are new measures that were not previously announced. One relates to one I was

Finance committee  Perhaps I'll provide just a bit of explanation. Foreign tax credit generators seek to create foreign tax credits for Canadian taxpayers by taking advantages of differences in the way tax laws work in Canada and in other jurisdictions, for example, the United States. We tax on t

Finance committee  I certainly read it.

Finance committee  For parts of it, this is the third time this bill has been before Parliament. It's consistent with the policy. The consultations have been undertaken in respect of the vast majority of it. In terms of how the tax system and tax law interact with individual taxpayers, certainly th

Finance committee  Certainly within the tax legislation division, tax policy branch, we have strong connections with the OECD, and various people within the branch are members of various committees. Some of the committees are chaired by CRA representatives. So certainly we're tied in to the OECD, a

Finance committee  Perhaps I'll just outline a few areas and then pass it to various colleagues who can speak to the specific parts. Obviously I would say part 1 relates to non-resident trusts and foreign investment entities. Parts 2 and 3 relate to foreign affiliates, and certainly we've already

Finance committee  Yes, it is a difficult question to address. Do you mean by the bill itself?

Finance committee  Certainly parts 1, 2 and 3 are aimed at particular taxpayer groups. Bijuralism, theoretically to the extent that you're reflecting both legal traditions in Canada, would have broad application. We've just been talking about charitable donations. The flip side of the measures th

Finance committee  That question can be addressed at many different levels. As I indicated earlier, in terms of having draft legislation that has not been enacted, it makes life more difficult for both taxpayers and the CRA, for example, because they may file their tax returns based on the draft le

Finance committee  In terms of the implications of this bill, it has certainly represented a significant overhang in terms of the Department of Finance's work. This bill required a lot of work, and each iteration of it has required maintenance and checking and things like that. Certainly those are

Finance committee  I think what you're referring to is that there are some amendments in Bill C-48 that relate to charitable donations. Certainly it had come to the attention of the Department of Finance and the CRA that people were engaging in schemes where works of art or other articles would be

Finance committee  I think the first release of technical amendments contained in this bill probably goes back to December 2002.

Finance committee  As I indicated, there's been consultation on the vast, vast majority of the measures included.