The Canada Revenue Agency (CRA) is undoubtedly one of the largest departments any Canadian or Canadian business faces. Apart from the "dreaded" submission of taxes
every April, the CRA renders a number of tax rulings every month with enormous impact on businesses. Needless to say, it is in every association executive and business owners' interest to understand this agency and have expert advice in navigating this department.
Should your organization need review of an interpretation or regulation, the key in navigating CRA is understanding where to bring issues of contention and raise concerns. While the CRA is an independent agency, it reports to the Minister of National Revenue. The Minister responsible for CRA is Carol Skelton.
The Minister of National Revenue is accountable to Parliament for all the CRA's activities, including the administration and enforcement of the Income Tax Act and the Excise Tax Act. The Minister ensures that the CRA operates within the overall government framework.
Her responsibilities also include liaising with the agents who run CRA:
Role of the Board of Management
The Board of Management consists of 15 members appointed by the Governor in Council. Eleven of these members have been nominated by the provinces and territories. The Board has the responsibility of overseeing the organization and management of the CRA, including the development of the Corporate Business Plan, and the management of policies related to resources, services, property and personnel.
The CRA's Board of Management is not involved in all the CRA's business activities. It does not have the authority to administer and enforce legislation or to access confidential client information.
Role of the Commissioner - Chief Executive Officer
As the CRA's chief executive officer, the Commissioner is responsible for the day-to-day administration and enforcement of program legislation that falls under the Minister's delegated authority. The Commissioner is accountable to the Board of Management for the daily management of the CRA, supervision of employees, and implementation of policies and budgets.
Moreover, the Commissioner must assist and advise the Minister with respect to legislated authorities, duties, functions, and Cabinet responsibilities.
The Role of the Chair
As the presiding director of the Board of Management, the Chair manages the affairs and functioning of the Board and guides the Board to ensure it meets its responsibilities.
Lobbying for policy change
Tax rulings and the understanding of them in their application is a complicated process. If your interest is in affecting change on a macro level, your best focus would be on the above apparatus. As with most other departments, it's important to know your 'targets' and focus on relationships. Because the board of the CRA, is of a provincial nature with appointments coming from the provincial capitals, your best bet would be to think of your issue along regional lines.
For those concerned with micro levels of concerns or disputes more specific to an individual company's interest, there are a number of interesting initiatives. For example, the Minister had recently announced the creation of the Office of the Taxpayer's Ombudsman. Other interesting links can be found at: CRA's website.
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Mark Buzan is the owner of Action Strategies, a public affairs & marketing communications consultancy. He brings a number of years of understanding of working with the Canada Revenue Agency and was the Executive Assistant to the Official Opposition Critic for National Revenue at the time of the agency's creation. You can subscribe now to his monthly public affairs newsletter by visiting the newsletter section of his website.