Bill S-2 · 37th Parliament · Jean Chrétien
Tax Conventions Implementation Act, 2002
An Act to implement an agreement, conventions and protocols concluded between Canada and Kuwait, Mongolia, the United Arab Emirates, Moldova, Norway, Belgium and Italy for the avoidance of double taxation and the prevention of fiscal evasion and to amend the enacted text of three tax treaties
Government bill. Became law.
- IntroducedOct. 1, 2002
- Debated in principleOct. 22, 2002
- Studied by a committeeDone
- Passed its first chamberOct. 29, 2002
- Passed the second chamberNov. 28, 2002
- Became lawDec. 11, 2002
Leading supporters
Ranked by the part each played: who is responsible for the bill, who carried it, and who spoke for it most.
- Jean ChrétienPrime Minister
Who carries this bill
Arrows run from the person responsible to those who answer to them on this bill. The critic leads the Senate’s scrutiny and answers to no one on it.
Where members stand
Votes and debate for this bill have not been read yet.
How it changed on the way
2% of the text as introduced was changed or removed by the time it became law (70,434 words introduced, 70,281 passed).
minor changeintent kept
The bill kept its core purpose of implementing the listed tax treaties with only minor technical fixes and added provisions for earlier treaties. A few sections on inconsistent laws, application dates, and schedule replacements were adjusted or inserted during passage.
- Added royal assent date to the long title.
After: “[Assented to 12th December, 2002]”
How precisely it is written
mostly preciseChallenging the law: HardDisputing a charge: Moderate
The bill relies on many defined terms, fixed percentages such as 10 per cent and 15 per cent, and five-year time limits that create clear rules. A few phrases still require judgment calls and the regulation power is written broadly.
Open to argument
“any regulations that are necessary for carrying out the Agreement or for giving effect to any of its provisions”
The word 'necessary' and the open-ended phrase 'giving effect to any of its provisions' set a subjective standard for what the Minister may regulate.“make an appropriate adjustment”
The term 'appropriate' invites argument over what adjustment meets the test.“substantially supported from the public funds”
The adverb 'substantially' is a matter of degree rather than an objective threshold.
Clear-cut
“the tax so charged shall not exceed 10 per cent of the gross amount of the interest”
A fixed numerical ceiling removes discretion on the maximum rate.“after the expiry of the time limits provided in its national laws and, in any case, after five years from the end of the year”
A hard five-year outer limit supplies an objective cutoff.
Discretion. The Minister of National Revenue is given an open-ended power to issue any regulations needed to carry out or give effect to each convention, leaving the scope of delegated authority to administrative judgment.
Challenging the law itself. The text contains no obvious vagueness or overbreadth that would engage section 7 or section 1 of the Charter in a facial challenge.
Disputing a charge under it. Most operative rules use defined terms and numeric caps, yet phrases such as 'appropriate adjustment' and 'ordinary course of their business' still allow factual disputes over application.
Read by a language model from the royal assent text; every quoted phrase appears in the bill. A reading of the drafting, not legal advice.
Did it work?
no evaluation found
Who lobbied on it
No lobbying registration naming this bill is loaded.
Stages and dates from LEGISinfo.