Joint Committee Submissions

The Joint Committee of Taxation of The Canadian Bar Association and the Chartered Professional Accountants of Canada

These submissions are provided courtesy of the Joint Committee and the opinions and views expressed therein are of the Joint Committee and not the Canadian Tax Foundation.

NOTE: For Joint Committee Submissions prior to 2006, go to Ask a librarian



 Impact of Pangaea Case  
 Guidance on international income tax issues raised by the COVID-19 crisis
June  COVID-19 Measures


December  Finance Comfort Letter - Cross-Border Surplus Stripping and Graduated Rate Estates
 Transfer Pricing Amendments
October  Employee Stock Option Amendments
September  Employee Stock Option Amendments
May Foreign Affiliate Dumping, Derivative Forward Agreement and Transfer Pricing Amendments Announced in the 2019 Federal Budget
May Employee Stock Option Changes Announced in 2019 Federal Budget
March Definition of “Public Corporation”


September Legislative Proposals Released July 27, 2018 
May   Reporting Requirements in Respect of Foreign Affiliates 
March  Joint Committe Submission - TOSI provisions on Dec 13
January Subsection 55(2) Amendments – Follow-Up to Our Meeting with Canada Revenue Agency
January  Joint Committee Submission – Response to Green case  


October  CPA Canada’s formal submission
October  Tax Planning Using Private Corporations - Tax on Split Income and Limitation of Lifetime Capital Gains Deduction Proposals
October  Tax Planning Using Private Corporations – “Converting Income into Capital Gains” Proposals 
October  Taxation of Private Corporations – Passive Income Proposals 
August Proposed Changes to the Voluntary Disclosure Program Announced June 9, 2017
June June 2017 - CRA-Small Business Deduction Rules in Section 125
May 2017 - Budget Amendments 1981
May 2017 - JCT Submission WIP
May 2017 - Standing Committee on Finance


November Technical Amendments Package of September 16, 2016
Finance Canada-Ted Cook_ 55(2) material and Part IV
Finance Canada-Ted Cook_Back to Back draft legislation
Finance Canada-Ted Cook_Subsection 152(9) draft legislation
Aug 25, 2016_Proposed Amendments to Small Business Deduction Entitlement and Transfer of Life Insurance Policies
July 25, 2016_Finance-Brian Ernewein_Federal Budget 2016-Proposed Amendment


 2015 Federal Budget - Proposed Amendments to Non-resident Employee Withholding Obligations
May   2015 Federal Budget - Synthetic Equity Arrangements
 2015 Federal Budget - Amendments to Section 55
June 19, 2015 - CBA-CPA Canada JCT Finance Submission_Federal Budget 2015
June 19, 2015 - CBA-CPA Canada JCT Finance Submission_Federal Budget 2015
Oct 13, 2015 - CBA-CPA Canada JCT Submission_Charitable gifting rules 
Nov 12, 2015 - CBA-CPA Canada JCT Submission Proposed Amendments to Section 55 and Related provisions 


The Recent LRE Amendments, December 23, 2014
September Joint Submission: 2014 Federal Budget Amendments to Trust and Estate Rules
June Joint Submission: Income Tax Folio S1-F5-C1
May        Joint Submission: Consultations on Treaty Shopping, May 16, 2014


December Joint Submission: Treaty Shopping
December Joint Submission: Testamentary Trusts
October  Department of Finance, August 16, 2013 Amendments 
October  Department of Finance, September 2013 Draft Legislation 
September  Joint Submission: Department of Finance, July 12, 2013 Amendments  
August  August 2013 - Notice of Ways and Means Motion / Bill C-48, the Technical Amendments Act, 2012 
Tax Incentives for Charitable Giving in Canada 
February December 21, 2012 Technical Amendments  


September  August 14, 2012 Draft Legislative Proposals to Amend the Income Tax Act (Canada) 
September  Legislative Proposals Released on July 25, 2012 
June  2012 Federal Budget – International Taxation Proposals
June   CBA / CICA Joint Committee Receives Letter from Department of Finance on RRSP/TFSA Changes 
January Functional Currency Rules 


December  October 31, 2011 Draft Legislation 
November  Bill C-13 – Corporate Tax Deferral Rules in Sections 34.2, 34.3 and 249.1 of the Income Tax Act (Canada) 
November  November 7, 2011 – Proposed Income Tax Amendments on Contingent Liabilities – Section 143.4  
October  Submission in Respect of the August 19, 2011 Foreign Affiliate Proposals 
October  Bill C-13 - Proposed Changes relating to RRSPs and RRIFs 
January December 16, 2010 Draft Legislation – Real Estate Investment Trusts 


November  Letter to the Minister of Finance on August 27, 2010 Draft Legislation — Information Reporting of Tax Avoidance Transactions 
October  Income Tax Act—Addendum on September 27, 2010, Submission on August 27, 2010—Draft Legislation 
September July 16, 2010 Draft Legislation re: Income Tax Technical Amendments 
  Information Reporting of Tax Avoidance Transactions (Solicitor - Client Privilege) 
  August 27, 2010 Draft Legislation re: 2010 Budget Proposals and Other Previously Announced Initiatives ("Draft Legislation") 
July  Income Tax Act—Information Reporting of Tax Avoidance Transactions 
May  Income Tax Act—March 2010, Notice of Ways and Means Motion
  Income Tax Act—Budget Proposals for Non-Resident Trusts and Foreign Investment Entities 
  Convertible Debentures   
April  Income Tax Act—Interpretation Bulletins 
February  Income Tax Act—Technical Amendments Relating to the Taxation of Foreign Affiliates 


September Proposed Declaration Process for Applying Treaty Benefits to Income Paid to Non-Residents  
April Recommendations regarding the Aggressive Tax Planning Working Paper released by the Québec Minister of Finance and Minister responsible for Infrastructure in January 2009
January  Non-Resident Trusts and Foreign Investment Entities 


September Specified Investment Flow-through ("SIFT") Conversions — July 14, 2008 Draft Legislation: Submission to Finance Canada 
July Canada's System of International Taxation: Submission to Finance Canada, July 15, 2008 
January Bill C-10, An Act to amend the Income Tax Act 

Fifth Protocol to the Canada-United States Income Tax Convention 


December Income Tax Act — Tax Provisions of Federal Budget 2007 : Submission to Finance Canada 
October Income Tax Act — Tax Provisions of Federal Budget 2007: Submission to Finance Canada 
June Foreign Affiliate Rules 
May  Income Tax Act — Foreign Affiliate Rules 

International Fair Tax Initiative 

Bill C-33 — Income Tax Act ss. 52(3)(a) and 53(1) — Stock Dividends and Paid-Up-Capital (PUC) 

February Income Trusts and Other Flow-Through Entities 
January Specified Investment Flow - Through Trusts and Partnerships 


December Eligible Dividend Rules 
September Income Tax Act - Taxation of Dividends 
June Income Tax Act — Proposals for Next Technical Amendments Bill 
April Outstanding Income Tax Proposals 
January Income Tax Act - Technical Amendments 

Income Tax Act - Section 143.3 - Employee Stock Options - Impact on Corporations

Additional Submission — Foreign Affiliate Rules: Submission to Finance Canada