Bill S-6 · 42th Parliament · Justin Trudeau
Canada–Madagascar Tax Convention Implementation Act, 2018
An Act to implement the Convention between Canada and the Republic of Madagascar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income
Government bill. Became law.
- IntroducedOct. 15, 2018
- Debated in principleNov. 20, 2018
- Studied by a committeeDone
- Passed its first chamberDec. 10, 2018
- Passed the second chamberMay 14, 2019
- Became lawMay 26, 2019
Leading supporters
Ranked by the part each played: who is responsible for the bill, who carried it, and who spoke for it most.
- Justin TrudeauPrime 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
1% of the text as introduced was changed or removed by the time it became law (9,771 words introduced, 9,768 passed).
How precisely it is written
mostly preciseChallenging the law: HardDisputing a charge: Moderate
The bill relies on defined terms, fixed percentages, and time limits that make most tax obligations clear. A few phrases still leave room for interpretation by officials or courts.
Open to argument
“The Minister of National Revenue may make any regulations that are necessary for carrying out the Convention”
Uses a broad necessity standard that grants wide regulatory power without objective limits.“that other State shall make an appropriate adjustment”
Subjective term 'appropriate' invites disagreement over the size of any tax change.“funded wholly or substantially by public funds”
The word 'substantially' lacks a numerical threshold and requires judgment.
Clear-cut
“after eight years from the end of the year”
Fixed eight-year limit supplies an objective cutoff for reassessments.
Discretion. Section 5 leaves the Minister of National Revenue broad power to issue any regulations deemed necessary, and several articles require competent authorities to consult or determine adjustments when facts are disputed.
Challenging the law itself. The Act implements an international tax treaty with detailed definitions and numeric limits, making a successful vagueness or overbreadth challenge under section 7 of the Charter unlikely.
Disputing a charge under it. Most rules use fixed percentages and time bars that are easy to apply, yet phrases such as 'appropriate adjustment' or 'wholly or substantially' could still be disputed in specific cases.
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.