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Tax Court of Canada Cour Canadienne De L’Impôt Tax Court of Canada Cour canadienne de l’impôt MEMORANDUM TO: Chief Special Trial Judge Panuthos, United States Tax Court FROM: Associate Chief Justice Lamarre and Isida Ranxi, Tax Court of Canada DATE: July 17, 2015 ASSIGNMENT: Notes re: Washington, DC Presentation of November 18-19, 2015. 1. Purpose of the Memorandum ................................................................................................. 1 2. Answers to Your Outline Questions ...................................................................................... 1 4. Thoughts on the Proposal ..................................................................................................... 10 5. Links to Share with Other Panel Members ........................................................................ 12 1. Purpose of the Memorandum This memorandum outlines my answers to your proposed questions, provides some thoughts on the panel’s discussion, suggests that an additional section be added to the proposal, and provides links to materials that may be of interest to the members of the panel, specifically as they pertain to information regarding the Tax Court of Canada and the Canadian legal system. 2. Answers to Your Outline Questions You have proposed an outline that addresses the following questions and my responses to them are the following. (A) Independence of the Judiciary a) What is the appointment process, and tenure of your Court? 1 In Canada, the appointment and administration of judges is governed by Part VII of the Constitution Acts of 18671 and 19822 and the Judges Act3. The federal government appoints judges to our Court through the Governor General on the advice of the federal Cabinet.4 A recommendation for appointment is made to Cabinet by the Minister of Justice (the “Minister”) with respect to the appointment of puisne judges, and by the Prime Minister with respect to the appointment of Chief Justices and Associate Chief Justices. The recommendation to Cabinet is made from amongst the names which have been previously reported by committees to the Minister.5 Before recommending an appointment to Cabinet, the Minister may consult with members of the judiciary and the bar, with his or her appropriate provincial or territorial counterparts, as well as with members of the public.6 The Minister also welcomes the advice of any group or individuals on the considerations which should be taken into account.7 The Commissioner for Federal Judicial Affairs Canada (the “Commissioner”) is responsible for the administration of the appointments process on behalf of the Minister.8 He must carry out his responsibilities, directly or by his delegate, in a way that ensures the system treats all candidates for judicial office fairly and equally. As part of his duties, the Commissioner administers the advisory committees, which assess the qualifications of the lawyers who apply for federal judicial appointments.9 Persons who wish to be considered for appointment as a judge of our Court must apply to the Commissioner.10 Members of the legal community and all other interested persons and organizations may also nominate persons they consider qualified for judicial office; the Commissioner then contacts the nominees to find out whether they wish to be considered for a judicial appointment.11 The qualifications for appointment are set out in the Tax Court of Canada Act (the “TCCA”)12, and read as follows: 4. (3) Subject to subsection (4), any person may be appointed a judge of the Court who (a) is or has been a judge of a superior court in Canada; (b) is or has been a barrister or advocate of at least ten years standing at the bar of any province, or (c) has, for an aggregate of at least ten years, 1 Constitution Act, 1867 (UK), 30 & 31 Vict, c 3, reprinted in RSC 1985, App II, No 5. 2 Constitution Act, 1982, being Schedule B to the Canada Act 1982 (UK), 1982, c 11. 3 RSC, 1985, c J-1. 4 Department of Justice Canada, The Judiciary (7 May 2015), online: <http://www.justice.gc.ca/eng/csj-sjc/ccs- ajc/05.html> [Justice Canada, The Judiciary]. 5 Ibid. 6 Ibid. 7 Ibid. 8 Department of Justice Canada, How Does Canada’s Court System Work? (7 May 2015), online: <http://www.justice.gc.ca/eng/csj-sjc/ccs-ajc/01.html> [Justice Canada, Court System]. 9 Ibid. 10 Ibid. 11 Ibid. 12 RSC 1985, c T-2 [TCCA]. 2 (i) been a barrister or advocate at the bar of any province, and (ii) after becoming a barrister or advocate at the bar of any province, exercised powers and performed duties and functions of a judicial nature on a full-time basis in respect of a position held pursuant to a law of Canada or a province. Independent judicial advisory committees constitute the heart of the appointments process. The committees assess the qualifications for appointment of the lawyers who apply.13 The Minister, with the assistance of the Commissioner, selects persons to serve on each committee who reflect factors appropriate to the jurisdiction, including geography, gender, language and multiculturalism. Committee members are then appointed by the Minister to serve a three-year term, with the possibility of a single renewal. The Minister meets periodically with the Chairs of all the committees for an exchange of views concerning the operation of the process.14 All committee proceedings and consultations take place on a confidential basis.15 The Committee for our Court is made up of 5 members: one judicial nominee designated by the Chief Justice of our Court and four nominees of the Minister appointed to reflect Canada's linguistic and geographic diversity. There must be at least one member from each of the following regions: Maritimes, Quebec, Ontario and Western Canada. The committee undertakes extensive consultations in both the legal and non-legal community for each applicant.16 The primary qualifications of judges are professional competence and overall merit.17 Committee members are provided with Assessment Criteria for evaluating fitness for the bench, which relate to professional competence and experience, personal characteristics, and potential impediments to appointment. Committees are encouraged to respect diversity and to give due consideration to all legal experience, including that outside a mainstream legal practice.18 Judges of the Tax Court of Canada are required to cease holding office when they turn 75 years of age.19 Subject to the age limit, judges may hold office during good behaviour, and are removable by the Government General on address of the Senate and House of commons.20 b) What is the relationship of your Tax Court with other parts of government, the executive and the legislative branches? Canada’s judiciary is one branch of our system of government, along with the legislature and the executive.21 The judiciary resolves disputes according to law. The legislature (Parliament) has the power to make, alter and repeal laws. The executive branch (in particular, the prime minister and ministers, the public service, as well as a variety of agencies, boards, and commissions) are responsible for administering and enforcing the laws in place.22 13 Ibid. 14 Ibid. 15 Ibid. 16 Ibid. 17 Ibid. 18 Ibid. 19 TCCA, supra, s 7(2). 20 Ibid, s 7(1). 21 Justice Canada, Court System, supra. 22 Ibid. 3 Judicial independence is a cornerstone of the Canadian judicial system.23 For this reason, under the Constitution, the judiciary is separate from and independent of the other two branches of government, the executive and legislature. Judicial independence guarantees that judges will be able to make decisions free of influence and based solely on fact and law.24 c) In particular are there pressures from the tax enforcement agency or from the public? The Tax Court is independent of the Canada Revenue Agency (the “CRA”) and all other government departments.25 To the Canadian government, the principle of judicial independence has three components: security of tenure; financial security; and administrative independence.26 As part of Canada’s commitment to administrative independence, no one can interfere with how courts manage the legal process and exercise their judicial functions.27 For instance, only the chief justice can choose how cases are assigned to the judges of his or her court.28 Several institutions have been established to support judicial independence, which include the Canadian Judicial Council, the Commissioner for Federal Judicial Affairs, the National Judicial Institute and the Courts Administration Service. These institutions help keep the government and the judiciary separate in areas like discipline, pay and benefits, and continuing education for judges.29 d) How does your Court fit within the general Court system in your country? How does your Court respond to reviewing higher Courts? The federal government of Canada has created specialized courts to deal more effectively with certain areas of the law.30 These courts have been created by statute and can only decide matters that fall within the jurisdiction given to them by those statutes. These specialized courts include the Tax Court of Canada, which deals with tax matters defined under the TCCA31. Our Court is a superior court that determines cases and appeals about matters that arise under federal tax and revenue legislation. It hears disputes between the federal government and taxpayers after the taxpayer has pursued all other avenues provided for by the Income Tax Act (the “ITA”)32. Appeals from our Court are heard by the Federal Court of Appeal. The latter court’s decisions can only be appealed to the Supreme Court of Canada. The Supreme Court hears most legal matters under federal jurisdiction or that involve the federal government. Two of its basic roles are to ensure that federal law is applied consistently throughout Canada; and to provide an avenue of appeal from decisions of the Tax Court of Canada and the Federal Court.33 23 Justice Canada, The Judiciary, supra. 24 Ibid. 25 Department of Justice Canada, Courts and Other Bodies Under Federal Jurisdiction (7 May 2015), online: <http://www.justice.gc.ca/eng/csj-sjc/ccs-ajc/03.html> [Justice Canada, Courts].
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