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Schizophrenia
Society of Canada
Le 11 août 2003
Ms SherriTorjman
Mr. Robert Brown
Co-Chairs, Technical Advisory Committee
c/o Mr. Charles Smith
Secretary, Technical Advisory Committee
Personal Income Tax Division, Department of Finance
140 O'Connor Street
Ottawa, Ontario K1A 0G5
Further to your request
of June 9, 2003, the Schizophrenia Society of Canada (SSC) would
be pleased to have our November 2001 submission to the House of
Commons Sub-Committee on the Status of Persons with Disabilities
of the Standing Committee on Human Resources Development and the
Status of Persons with Disabilities posted on the Committee's Web
site at www.disabilitytax.ca.
However, given that CCRA
has taken many of our initial recommendations into consideration
and appears to be addressing the rigid nature of the Disability
Tax Credit (DTC) form, we would like to add this letter as an addendum
to our original position.
While we are encouraged
that CCRA seems to be exploring the allowance of more qualitative
responses on the form and is showing a willingness to review cases
in a more humane time-frame, there still remains the issue of the
Income Tax Act itself.
The current language
of the Act needs to address the fact that not all disabilities are
prolonged, that is "last or are expected to last for a continuous
period of at least 12 months." It is necessary to redefine
prolonged to incorporate impairments that are substantial, persistent
and recurrent so as to recognize the episodic nature of mental illness.
By doing this, it would allow those affected by mental illness and
other episodic disabilities to receive the DTC without delay and/or
appeal.
CCRA has gone as far
as it can in its role to amend the DTC form but we recognize that
we are in the middle of the process of creating significant and
meaningful changes to the tax credit. We are encouraged that CCRA
has engaged organizations like SSC in this process and should therefore
address the issues expressed in our original 2001 brief.
However, the key stumbling
block to ensuring the eligibility of the DTC is inclusive of all
disabilities remains the Income Tax Act. We are in agreement with
the submission of the Coalition for Disability Tax Credit (DTC)
Reform and now call for a change to the Act itself.
Thank you again for taking
an interest in our concerns regarding the eligibility for the DTC.
Sincerely,
Joan Montgomery
CEO, Schizophrenia Society of Canada
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