Comment Letters

TEI Comments on Proposed Penalty for Canadian GAAR

On May 31, 2023, TEI filed comments with the Canadian Department of Finance regarding a proposal to impose a penalty on taxpayers who violate Canada's general anti-avoidance rule ("GAAR"). TEI commented that a distinct penalty for violations of the GAAR was not necessary given the current structure of the Canadian income tax code. Should the Canadian government implement such a penalty, TEI recommended that the penalty only be imposed in cases where the taxpayer acted with "gross negligence" or a similar level of fault, among other things.

TEI Comments on Proposed Changes to Canada’s Income Tax Mandatory Disclosure Rules

On December 10, 2021, TEI submitted comments to the Department of Finance concerning the proposed changes to Canada’s income tax mandatory disclosure rules described in Budget 2021. TEI’s comments focus primarily on the government’s proposals to amend the Income Tax Act’s reportable transaction rules and introduce a new requirement for specified corporations to proactively report uncertain tax positions to the Canada Revenue Agency.

TEI Comments on the Build Back Better Act’s Corporate and International Tax Reform Proposals

On December 9, 2021, TEI issued a compilation of substantive comments and recommendations concerning select corporate and international tax reform provisions in H.R. 5376, the Build Back Better Act, as passed by the House of Representatives on November 19, 2021. This submission represents the culmination of several months’ worth of consultation with members of TEI's Tax Reform Task Force and other standing committees, who contributed an array of perspectives and concerns from across the industry spectrum.

TEI Comments on Canadian Government’s Proposed Digital Services Tax

On June 18, TEI submitted comments to the Canadian Department of Finance regarding the Canadian Government’s proposed tax on digital services (the DST). TEI’s comments focused on the practical compliance issues businesses will face should the proposed tax be enacted into law.

TEI Issues Guideposts for Tax Policy in the 117th Congress

On May 11, 2021, TEI officially weighed into the brewing tax reform debate in Washington, D.C., through the issuance of its new Guideposts for Tax Policy.  The guideposts are intended to highlight a series of high-priority, broadly applicable principles of sound tax policy to inform the current deliberations in the 117th Congress and Biden administration.  They are also intended to lay a solid, principles-based foundation to support TEI’s substantive, issue-focused advocacy activities in the weeks and months ahead.  TEI encourages policymakers to adopt these guideposts

TEI Comments on Canadian Government’s Fall Economic Statement

On January 29, TEI submitted comments to the Canadian Department of Finance regarding certain items in the Department’s fall economic statement, including issues related to proposed new rules on cross border digital products and services, as well as goods supplied through fulfillment warehouses.

TEI Files Comments on OECD Pillar One and Pillar Two Blueprints

On December 13, TEI submitted comments to the OECD regarding its BEPS Project Pillar One and Pillar Two Blueprints. TEI’s comments focused on the specific questions posed by the OECD in its consultation document, including issues related to Amounts A and B under Pillar One, as well as the GloBE under Pillar Two.

TEI Requests European Commission Intervention to Assist Businesses Survive COVID-19 Disruptions

On November 2, 2020, TEI submitted a letter to the European Commission requesting VAT-related intervention to assist businesses survive COVID-19 disruptions.

TEI Submits Comments to the IRS Concerning the Proposed Elimination of Revenue Procedure 94-69

On October 16, 2020, TEI submitted comments to the Large Business & International Division of the IRS urging the division to retain Rev. Proc. 94-69 and extend it to all taxpayers subject to the Large Coordinated Case Program.

TEI Members Provide Feedback on CRA Draft of Simplified Form T2200, Declaration of Conditions of Employment for Working at Home During COVID-19

On September 15, 2020, following an intensive effort to survey TEI members working for companies in different industries across Canada, TEI’s Canadian Income Committee submitted a compilation of responsive, actionable comments to the CRA concerning the draft form.
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