by Caitlin Butler CPA, CA
Consider this… Two teams, two coaches and a few referees participating in a good old hockey game. All, by and large, understand the rules and if someone fouls, the ref calls it and penalizes. This is analogous to taxes – the players are taxpayers, coaches are advisors and CRA is the referee trying to administer the tax rules as drafted by the Department of Finance.
Normally, what happens when the rules change? Players, coaches and the referees learn the changes, suggest tweaks to make them more efficient, and then they comply. The game carries on.
What happens if the rule changes are so convoluted and complicated that the coaches, players or referees cannot fully understand them or apply them to their situation? Potentially a lot of things, many of which are not good for anyone involved, including the good old hockey game.
Perhaps, players and coaches take advantage of the ambiguity and push the envelope. Some may play it particularly safe so as to not offend. Some may get frustrated and stop playing. Others may completely disregard the rules, but continue playing. The refs are left to deal with the chaos. Bottom-line – the quality of the game suffers greatly.
It doesn’t seem fair to anyone involved – taxpayers, advisors, CRA or the observers of the game.
This is how I, and many others, that have carefully analysed the proposed tax changes, perceive the impact. Without clarity and simplicity, one can’t fully comply as intended. All involved are set up to fail. How does that impact the overall integrity of Canada’s self-assessment tax system?
Regardless of your position on the policy behind the proposals, I think we can all agree on one thing – the rules must be clear and understandable. At a minimum, provide taxpayers the opportunity to comment and comply. The proposals, as drafted, don’t do this.
If there is too much tripping or abuse in the game, changes the rules. But, make sure that they are clear enough so that the game doesn’t freeze in confusion, or worse.
Let’s slow down and clarify the rules so that the game can go on.
If you want better dialogue and consultation, consider signing this petition. https://www.videotax.com/petition