Understanding the Taxman: Canada Revenue Agency

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.

Is there a right or wrong time to launch a GR campaign?

Recent discussions I held with a client of mine helped me put this question into perspective. As for many association executives, resources are limited and any effort put forward needs to be assured a reasonable chance of success. As a result, I began thinking of the five criteria an executive should consider as indicators of true opportunities for change in government policy:

1. The most obvious to identify is where a sitting government has established its priorities. For example, what has the most recent budget or Speech from the Throne stated? Listing through the government priorities provides an organization the chance to do some very positive introspection.

2. Where does public opinion stand? When the tories came to power last year, few expected the environment to be as hot a subject as it is now. Their platform addressed the subject but it was clear that they had other priorities. Now that the environment has become a bigger priority for Canadians, government funding initiatives for the environment have taken a much bigger priority. In turn, the issues and concerns of the environmental lobby have also been heeded.

3.Honestly, are your expectations reasonable? Given what you know of your issue and the possible complexities involved, it's important to understand whether your position will fit with the government or carry any weight with complementary stake holders. For example, in an age where subsidies to public advocacy groups are on the decline, is it reasonable to set your benchmarks of success at $1 million of funding when the likelihood of receiving several thousand dollars will be challenging enough?

4. Who currently has the ear of policy makers? This is where the importance of a government relations audit is so crucial. Have opposing pressures or groups made gains ahead of yours, producing a situation wherein they are better positioned to have the ear of parliamentarians, legislators, and bureaucrats? If they have, are there alternative routes your organization can take? If not, when will the next best opportunity come?

5. Timing, timing, timing! Many factors can play into the success of a government relations campaign. Few however, have such a prominent role as timing. Examples of knowing when to launch a campaign include:
-The announcement of a coming commission or consultation process
-In advance of any budget, provincial or federal, committee hearings take place. Make sure to pay attention and participate. In last month's entry, I touched on the how-to's of presenting to committees.
-Opinion polls and media attention. If trends seem to be taking a direction different from the current government's, offering your solution to bridge the gap dramatically increases your chances.

Take these points to heart. They provide a unique opportunity for you to audit your government relations chances. Investing in an audit with an experienced GR consultant can save your organization time, effort and money down the road. Let me know if I can help,

Mark
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Mark Buzan is the owner of Action Strategies, a public affairs & marketing communications consultancy. You can subscribe now to his monthly public affairs newsletter by visiting www.actionstrategies.ca and dropping down the newsletter menu.

The How-to's of Commissions, Consultations, & Committees

The challenge of presenting before a commission or committee is ensuring that your message stands a reasonable chance of being adopted. Witnesses must make the best of their testimony. They must get an edge over other groups which compete for the ear of the member. Expert witnesses are not necessarily expert communicators. While many preliminary steps are required to get ready, the following “last minute checklist”, conducted just prior to appearing, might help you take your message to the Hill.

Whether it is to present a case on a fact-finding enquiry or to be embroiled in debate on the merits or costs of clauses in a bill, committees enable Canadians to intersect the policy and legislative process. Parliamentary committees are also the place where members truly roll-up their sleeves to delve into the issues.

Of course, all public policy advisors would agree on one key point: that to influence the policy-making process its best to get in at the earliest stages. This confirms the importance of the constant flurry of departmental consultations, caucus briefings and private one-on-one meetings between parliamentarians and groups. Still, parliamentary committees are unmatched in channelling Canadians’ views to government.

There are other compelling reasons for witnesses to enhance their committee performance. A committee visit may involve managing media relations; testimony may be of interest to ministers or regulators; what is raised at committee could become an issue in Question Period (which is particularly significant for public servants). If CPAC is covering the hearing, a witness is also communicating to a national TV-audience. In short, a committee appearance can be a linchpin for broader communication efforts. (This explains why groups may use committees to table fresh research or announce new initiatives.)

Effective testimonies can also hinge on whether a relationship has been developed with members or those in the bureaucracy who may have organized the consultation process. Witnesses that just blow into town for one meeting, drop their testimony and leave risk being marginalized. Seasoned witnesses rarely air their solutions with members for the first time at the committee table. Working at the constituency level, for instance, helps familiarize members to the issues. The rule of thumb for witnesses appearing before committees is tailor your strategy.

Also crucial is finding additional partners with whom which you could partner, double up, or reciprocally further back a position. As mentioned in Corridors, Action Strategies' Government Relations Newsletter, we've been working with a national trade association looking to present before Quebec's Energy Efficiency Agency. Crucial to this process has been identifying partners and determining the relevance of the message we have to offer.

In future postings, I'll get more into detail on the make ups of committee hearings and how they can be best leveraged.
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Mark Buzan is the owner of Action Strategies, a public affairs & marketing communications consultancy. You can subscribe now to his monthly public affairs newsletter by visiting www.actionstrategies.ca and dropping down the newsletter menu.