Where is the respect for order of operations and for vulnerable people?

Minister Shea, thank you for taking the time to consider my requests for effective processing of multi-year, multi-family adjustments.

It's very serious that CRA doesn't respect cover letters from professionals. I am dismayed that you find that this is acceptable behaviour on the part of CRA, and not enough of a problem to take action. We professionals take our order of operations, as set out in the ITA in S. 118 very seriously.

As for Level 2 authorization provided to anyone who asks for it. I'm shocked that this continues to be acceptable. I guess it's going to take a very serious fraud before anything is done. Vulnerable people are at risk when ‘promoters’ pressure them for Level 2 access to their taxation records.

 Level 2 access exposes people to fraudsters who now have significant personal financial information about their history, their savings, their income and lifestyle and can now make changes to those records with impunity. Limiting the fees that 'promoters' can charge isn't the way to deal with this. Of course there are consequences, if and when fraudsters are caught, but why have we opened the door and invited them in?

I will not give up on my belief of two things. I'm not giving up on either of these causes and will continue to raise awareness that:

1) Level 2 leaves the vulnerable family of persons with disabilities exposed to fraudsters and that the legislation proposed to limit fees for ‘promoters’ is the wrong approach.

2) The ITA requires an order of operations for personal tax credits that requires respecting family adjustments enough that there is an allowance to process them simultaneously upon request by a professional tax preparer. The logistics of attempting to process these adjustments any other way is mind boggling. It's like working with a circular reference in a spreadsheet, there is no resolution without compromise.

Regards, Eileen Reppenhagen, CGA
www.taxdetective.ca 604-943-7414