Questions and responses 44th Parliament, 1st session November 22, 2021, to January 6, 2025

With regard to Canadian ambassadors and consuls general assigned to place in the United States, broken down by each individual and by year from January 1, 2021 to date: (a) how many days were the ambassadors or consuls general at the location or area where they are stationed (e.g. how many days was the Consul General of Canada in New York physically in the New York area); and (b) how many round trips did each ambassador or consul general make between Canada and their assigned post in the United States?

With regard to government measures taken in relation to United States President Joe Biden’s visit to Parliament Hill on March 24, 2023: (a) which individuals or entities were provided with lists of individuals who (i) may come into contact with the United States President or the Prime Minister of Canada, (ii) would be allowed into West Block or otherwise in the vicinity of the United States President on that date; and (b) which departments, agencies, or other government entities received any such lists as in (a)(i) and (a)(ii), and, for each one, which individuals or entities within the government received the lists, and from whom?

With regard to all memorandums, briefing notes, and other documents sent from or received by the Privy Council Office related to, or which mention in any way, the United States President Joe Biden’s visit to Parliament on March 24, 2023: what are the details of each, including the (i) date, (ii) sender, (iii) recipient, (iv) type of document, (v) title, (vi) summary of the contents, (vii) file number?

With regard to government information about the two Canadian Hells Angels named in an indictment in the United States: did the U.S. government notify the Canadian government of these two Canadians before the indictment was unsealed?

With regard to all memorandums, briefing notes, and other documents sent from or received by Global Affairs Canada related to, or which mention in any way, United States President Joe Biden’s visit to Parliament on March 24, 2023: what are the details of each, including the (i) date, (ii) sender, (iii) recipient, (iv) type of document, (v) title, (vi) summary of the contents, (vii) file number?

With regard to border crossings (land, bridge and tunnel) between Canada and the United States and the operations and facilities of the Canada Border Services Agency (CBSA): (a) what is the cost of overall operations of the CBSA at each border crossing location; (b) what are the operating and maintenance costs for buildings and facilities used by the CBSA at each border crossing; (c) how is the cost to (i) operate CBSA services, (ii) maintain buildings that are used by the CBSA, at each border crossing location paid for and by whom; (d) are there any agreements or other mechanisms where (i) border crossings provide financial support or services free of charge to CBSA or other government entities, (ii) CBSA or other government entities provide financial support or services free of charge to the border crossing, including buildings and facilities, and, if so, what are the details of each instance; and (e) for the new Gordie Howe Bridge crossing, how are the services and buildings and facilities maintenance for the CBSA going to be paid for and by what mechanism, since it is the only public-private partnership border crossing owned by the federal government?

With regard to Canada Border Services Agency (CBSA) officers serving the United States—Canada land border: (a) does the government consider the CBSA officers protecting the land border to be public safety officers; (b) what is the number of CBSA officers who have worked at CBSA for (i) under five years, (ii) five to 10 years, (iii) 10 to 15 years, (iv) 15 to 20 years, (v) 20 to 25 years, (vi) more than 25 years; and (c) how many CBSA officers are currently on (i) long-term leave, (ii) administrative leave, (iii) short-term leave, for health and safety reasons?

With regard to the government’s deal with Volkswagen to build a plant in St. Thomas, Ontario, and the Prime Minister’s claim that “There were places in the United States that were putting up way, way more money than we put on the table”: (a) which specific places was the Prime Minister aware of that made such offers; (b) through what sources did the government become aware of each of such offer; (c) how much more money did each place in (a) offer, broken down by location; (d) for each offer in (c), what non-monetary measures were included with the offer; and (e) what non-monetary measures did the government offer Volkswagen?

With regard to the government's reaction to reports that United States National Guard troops have been handing out bus tickets to migrants in New York City for travel to Roxham Road: (a) has the government made any representations with officials in the United States, including New York City municipal officials, to stop this, and, if so, what are the details of those representations, including the (i) date, (ii) government officials who made the representation, (iii) title of the official in the United States who received the representation; (b) what assurances, if any, has the government received that the handing out of bus tickets will stop; and (c) what is the government's estimate on the number of individuals who have crossed the border at Roxham Road after receiving these bus tickets?

With regard to Canadian sourced income and the definition of "permanent establishment": (a) why is working from home in Canada while logging into US-based companies' internet servers interpreted or considered as Canadian-sourced income by the Canada Revenue Agency (CRA); (b) is the CRA considering a commuter's home as a US company's permanent establishment or as the commuter's permanent establishment; (c) since the commuter's home is not US company property by any measurement, why does the CRA consider the commuter’s home as a US company’s permanent establishment or as the commuter’s permanent establishment of work and in turn how does neither case imply that the commuter and his home are therefore a small business entity generating Canadian-sourced income with deductible expenses; (d) if a commuter's home is considered a commuter's permanent establishment and the commuter is not employed by a Canadian company but provides services to a foreign company, why is the commuter not considered its own small business entity for Canadian tax purposes and not qualified for small business tax deductions; (e) if the commuter’s home is considered as a permanent establishment, why are commuter business expenses such as utilities, travel, rent, vehicle used and registration, etc. not allowed to be deducted as business expenses from their Canadian-sourced income; and (f) if a commuter’s home is considered a permanent establishment, why is going to another office from the commuter's home permanent establishment not considered as a business travel expense?

With regard to the double taxation of Canadian commuters working from home a few days per week for US-based companies and the impact on the Canada Revenue Agency (CRA) foreign tax credit of the Federal Insurance Contributions Act (FICA) taxes deducted in the US and the US 401(k) contributions via the CRA form RC268; (a) must employment be 100 percent exercised in the US per year in order to claim 100 percent of the FICA tax deductions as a foreign tax credit in Canada; (b) if the employment is partially exercised in the US while FICA taxes are deducted based on full employment income by US-based employer regardless of where employment is exercised, would only the percentage of FICA tax deductions equivalent to the percentage of days of employment is exercised in the US be eligible to claim as a foreign tax credit rather that the full actual FICA tax deduction amount; (c) if the answer in (b) is affirmative, why is it not possible for commuters to deduct (on a Canadian tax return via the foreign tax credit) the full FICA tax amount paid in the US based on full employment income even when working from home in Canada; (d) for the 401(k) US pension plan, if employment is only being partially exercised in the US while 401(k) contributions are being made 100 percent throughout the year regardless of where the employment is exercised, would only a percentage of the 401(k) contributions that matches the percentage of days that employment is being exercised in the US be eligible to claim on CRA form RC268; (e) if the answer in (d) is affirmative, is the combination of the lack of a tax deduction credit for the 401(k) portion not eligible to claim on RC268 and the income tax payable during retirement upon 401(k) funds withdrawal considered as double taxation, and, if not, why not; (f) is there a minimum percentage of time that employment must be "exercised" in the US so that Canadian commuters can claim 100 percent of their full year 401(k) contributions on form RC268; (g) if the requirement in (f) is 100 percent or if the answer in (a) is affirmative, could the Department of Finance Canada and the CRA clarify or work to have the convention modified to establish and allow a minimum requirement (a percentage of days of exercising employment in the US vs. total work days) with regard to being allowed to claim 100 percent of FICA taxes and 100 percent of 401(k) contributions; (h) why is the third qualifying bullet on form RC268 not allowed a deduction on the full-year 401(k) contributions (regardless of where employment is exercised); (i) would partially working from home in Canada disqualify Canadian commuters from claiming (i) 100 percent of their 401(k) contributions on Form RC268, (ii) a certain percentage of the full-year 401(k) contributions with respect to the percentage of employment exercised in Canada; (j) how does the Government of Canada, along with the CRA, abide by Article XXIV-ii (Elimination of Double Taxation), if (i) FICA taxes are not fully deductible in Canada through a foreign tax credit, (ii) the 401(k) contributions are disqualified or partially disqualified from being claimed on Form RC268 due to the form's third qualifying bullet?

With regard to the Government of Canada’s discussions with the United States of America on the Safe Third Country Agreement, since January 1, 2022: (a) how many meetings, virtual, in-person or by phone, have there been where Roxham Road was discussed; (b) for each meeting in (a), which public office holders participated in those discussions, including their full name and title; (c) what briefing documents, internal memos or emails were written in preparation for or as a result of those meetings; (d) which departments were involved in preparing for those discussions?

With regard to all memorandums, briefing notes, and other documents sent from or received by Global Affairs Canada related to, or which mention in any way, United States President Joe Biden’s visit to Parliament on March 24, 2023: what are the details of each, including the (i) date, (ii) sender, (iii) recipient, (iv) type of document, (v) title, (vi) summary of the contents, (vii) file number?

With regard to all memorandums, briefing notes, and other documents sent from or received by the Privy Council Office related to, or which mention in any way, the United States President Joe Biden’s visit to Parliament on March 24, 2023: what are the details of each, including the (i) date, (ii) sender, (iii) recipient, (iv) type of document, (v) title, (vi) summary of the contents, (vii) file number?