Assessment and collection of corporate income tax in Quebec, Ontario and Alberta : the problems of an independent approach in a federal jurisdiction

Seven provinces in Canada have entered tax collection agreements with the federal government whereby that government collects corporate income tax on their behalf. Quebec, Ontario and Alberta have not entered such agreements and levy and collect corporate income tax pursuant to their own legislation and within their own administrative systems. This thesis will examine the problems resulting from the independent approaches taken by Quebec, Ontario and Alberta, as they affect the corporate taxpayer. The problems fall into three categories. First, provincial adoption of the Income Tax Act (Canada), while assuring some similarity between the federal and provincial systems, can have adverse consequences for the corporate taxpayer. Secondly, differences between the legislation of Canada, Quebec, Ontario and Alberta create inconsistencies that present difficulties for the corporate taxpayer. Thirdly, differences in the administrative systems of the three provinces and the federal government increase the cost to the corporate taxpayer and create compliance problems for it. The thesis concludes that the future of the Canadian corporate income tax system will involve even more provincial independence and, therefore, measures to alleviate some of the problems are discussed. These include a new approach to co-operative federalism, an examination of the efficacy of more provincial autonomy and tax harmonization. This analysis shows that the corporate taxpayer would benefit from more cooperation between the federal and provincial governments together with a degree of harmonization of the tax bases