Multi-Employer Benefit Plan Council of Canada
May 7, 2018
Via Email: Department of Finance and the Canada Revenue Agency
The Multi-Employer Benefit Plan Council of Canada (MEBCO) is a non-profit corporation representing the interests of Canadian multi-employer pension and benefit plans. We are writing to submit our recommendations and comments with respect to the transitional rules and amendments to the Income Tax Act to govern the phase-out and conversion of Health and Welfare Trusts (HWTs) to Employee Life and Health Trusts (ELHTs). MEBCO previously made a submission on the Canada Revenue Agency's (CRA) Income Tax Folio S2-F1-C1 which was released in 2015. One of the concerns in the Folio submission related to the differential treatment of these two vehicles and MEBCO recommended harmonization of the HWT and ELHT rules. While MEBCO did not advocate for the sunset of HWTs, we appreciate that the CRA and Department of Finance has recognized MEBCO’s concerns and is taking steps to harmonize the rules albeit now under ELHTs only. MEBCO would be pleased to work with the CRA and Department of Finance to assist with the development of the transitional rules as a stakeholder advisor.
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