Auditor General Critical of Another CRA Effort to Identify Non-filers

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In our first article in this three-part series, we argued that the Canada Revenue Agency’s (CRA) Non-filer Benefits Letter Campaign was, at best, seriously underperforming on its intent, to get non-filers to file their outstanding returns.

In our second article, we look at what else the CRA may be doing to identify non-filers.  A February 2022 report from the Auditor General of Canada to Parliament (AG) entitled “Access to Benefits for Hard-to-Reach Populations” sheds further light on this question.  The report looks at the work of Employment and Social Development Canada (ESDC) in administering the Guaranteed Income Supplement (GIS) and the Canada Learning Bond (CLB), and the work of the CRA in administering the Canada Child Benefit (CCB) and the Canada Workers Benefit (CWB).

The AG focused on how well ESDC and the CRA are doing in getting these benefits to all residents who are eligible to receive them, what it calls the coverage rate.  Since the filing of a return is a condition for obtaining (CWB) or maintaining (GIS and CCB) the benefit, or again for establishing eligibility for the benefit (CLB), the CRA’s and ESDC’s work on the take-up gap, or the percentage of eligible residents who are not benefit recipients can inform the discussion about non-filers.

The AG found that “[ESDC and CRA] estimates overstated the take-up of benefits because they did not always account for people who had not filed tax returns, which are required to access most benefits.”  The AG also found that the CRA and ESDC “did not have a complete estimate of the overall take-up rates of the selected benefits.  Nor did they know the take-up rates of specific hard-to-reach populations known to experience barriers to accessing benefits.”  What was the CRA doing to improve its understanding of the size of the gap between eligible and actual benefit coverage?  The AG found that “[n]o tangible progress had yet been achieved in data collection, measurement, or analysis of benefit take-up.”

Finally, this article examines the relevance of the AG’s report to the CVITP.  CVITP host organizations know that one of the key barriers to filing a return is the lack of free return preparation services.  This is why these organizations offer CVITP services: they understand that, for the clients they serve (many of whom fall squarely within the hard-to-reach populations identified by the AG), providing this free service is critical to obtaining federal and provincial or territorial benefits which contribute toward reducing income-based poverty.

The first two articles in this series set the stage for what more the CRA could be doing to reach non-filers, the subject of the third and final article.

Disappointing Distraction: The CRA’s Non-filers Benefits Letter Campaign

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Two years ago, we posted an article on the issue of non-filers.  We are now updating this with a series of three articles.

The first article in this series looks at the Canada Revenue Agency’s (CRA) non-filer benefit letter campaign which has been running for six years.  This campaign entails the CRA sending letters to people who have not filed a return in the most recent tax season.  These letters outline the benefits of filing a return.  Then the CRA tracks whether or not the letter recipients file a return in the next tax season.

We argue that the performance of this campaign has been, at best, insufficient at dealing with the size of the non-filer problem.  Less charitably, we argue that it represents a minimalist effort on the part of the CRA.  Worse still, we believe the success of this effort, such as it is, is based on the faulty assumption that these letters actually motivate recipients.  Research commissioned by the CRA and others shows that a lack of knowledge about the benefits of filing is not identified as one of the main barriers to filing a return.  The CRA makes very little data available on this initiative but we strongly suspect that, even in the absence of this letter campaign, a similar number of non-filers from one tax season would likely file in the next.

This article lays the groundwork for a discussion in the next two articles of more effective approaches to addressing the issue.  As we hope will become readily apparent to the reader, the CVITP has an important, but as of yet vastly underexploited, role to play in helping to tackle this issue.

Trends in Poverty Reduction With Implications for the CVITP

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Our website is focused on the link between the CVITP and poverty reduction.  The federal government’s first ever Poverty Reduction Strategy, introduced in 2018, set a target for reducing the poverty rate by 2020 by 20% from its 2015 level.  In March 2022, the Official Poverty Dashboard of Indicators maintained by Statistics Canada indicated that the poverty rate, which was 14.5% in 2014, had declined to 6.4% in 2020.  This is well in excess of a 20% reduction!

However, Statistics Canada recently released a paper which revised the poverty rate for 2020 to 8.1%.  This revision took into account the 2021 Census of Population figures.  While not as impressive as 6.4%, it still exceeds the target the government set for reducing poverty by 2020.

But this accomplishment is likely to be short-lived for two reasons.

First, 2020 saw the introduction of a large number of benefits to help people who had suffered loss of income due to COVID related lockdowns.  While not the intended objective, these benefits lowered income inequality as well as the proportion of the population living on low incomes.  While many of these supports were maintained in 2021, these income supports were largely withdrawn in 2022 as the economy opened back up.

Second, 2022 has also seen rising price inflation.  Price inflation disproportionately impacts those on low incomes, reducing their purchasing power, as people in this group live on fixed incomes or low wages which do not rise as fast as inflation.

Whether or not these two factors have led to an increase in the poverty rate will only be known in March 2024 when Statistics Canada releases its poverty data for 2022.  The implications for the CVITP will be evident more immediately as an increasing number of residents fall into poverty, becoming eligible to receive federal and provincial or territorial government benefits which are income tested.  Since the filing of a current income tax and benefit return is a condition for receiving many of these benefits, the federal government will be keen to facilitate filing.

But will the CVITP be ready to provide this service in the 2023 season to an expanding clientele?  The most recent figures for the CVITP show, at the very least, that the CRA will struggle to do this. Consequently, many low-income people who are eligible for this service in 2023 will likely have to turn to commercial return preparers to file in a timely manner.  Others will file late, risking interruptions in the flow of their benefits.

For more details, see our full article on this topic here.

The Evolution of the CVITP – 2022 Update

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Canada Revenue Agency’s (CRA) recently released Departmental Results Report for fiscal year 21/22 allows us to complete the 2022 update for the evolution of the CVITP.  We have divided this subject into three short articles.  The first focuses on the results from delivering CVITP service to clients.  It includes all the data with accompanying commentary on individuals assisted, returns filed and value generated.  The second focuses on the CVITP infrastructure needed to provide this service.  It also provides all the data with accompanying commentary on host organizations and volunteers.  The third is a new feature which provides some simple measures of CVITP productivity.

Short on time?  Here are the key developments:

NO INCREASE IN CVITP SERVICE IN 2022

  • While the CRA calls the number for individuals assisted in the 2022 tax season an approximation, it is roughly the same as in the 2021 tax season; in other words, there has been no increase in service.  The 2021 tax season saw a partial rebound in numbers after the sharp decline in 2020 but it was still well below the numbers reached in 2016 and far from the peak in 2019. 
  • The trend for returns filed largely mirrors that of individuals assisted.
  • While the CVITP was making progress in filing more of its clients’ prior year returns up until and including the 2020 tax season, its performance in this area declined in 2022.
  • For the first time, the CRA has reported in its Departmental Result Report on value of the refund and benefits generated through the CVITP.  This is a very welcome development, and we hope that the CRA continues this practice in the future.  As the main rationale for offering a CVITP clinic is not to help individuals pay income tax but to help them maintain access to many poverty-reducing benefits, this figure provides tangible evidence of the real value generated for CVITP clients.

NUMBER OF HOST ORGANIZATIONS REBOUNDS BUT NUMBER OF VOLUNTEERS CONTINUES TO DECLINE

  • The number of host organizations offering CVITP service has largely rebounded in the 2022 tax season following the precipitous decline due to COVID health restrictions.
  • The trend in volunteers has been in decline since it peaked in the 2019 tax season.  The small rebound in the CRA count for 2022 is, we believe, misleading.  This is due to an unusual interpretation which the CRA makes in whom it classifies as a volunteer.  In partially correcting for this with an adjusted estimate, we show that the small rebound in 2022 is illusory and that the number of volunteers continues to decline.

PRODUCTIVITY REBOUNDS FOR VOLUNTEERS BUT NOT FOR HOST ORGANIZATIONS

  • Averages of individuals assisted and returns filed per volunteer fully rebound to the peaks achieved in the 2017 tax season.
  • Averages of individuals assisted and returns filed per host organization are only 70% and 71% respectively of the peaks achieved in the 2017 tax season.

For further analysis, charts with trends, tables with data and their sources, see:

How to Get Experienced Volunteers Back Next Year

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Once a CVITP volunteer has been recruited, trained and gained some experience, the CVITP stands to gain if the volunteer comes back again next year.  Given that the Canada Revenue Agency (CRA) does not publish information about its volunteers, we do not know if the root of the problem behind its stagnating volunteer numbers is principally one of poor recruitment of new volunteers or of poor retention of existing volunteers.

Just as with the recruitment of new volunteers, the CRA currently relies primarily on its host organizations’ efforts to retain their existing volunteers for the next tax season.  Yet the evidence suggests this indirect approach, mediated via its host organizations, is not working.  In this article, we propose ways for the CRA to get directly involved in efforts to retain its existing CVITP volunteers.

Volunteers need to be recognized for their efforts.  This is a fundamental aspect of any organization’s work on retaining its volunteer.  However, at present the CRA does remarkably little to recognize its CVITP volunteers’ contributions.

This article offers ideas for the CRA to better acknowledge their volunteers’ contributions both to the volunteers themselves and to the wider community.  It also includes some other measures the CRA could take to help retain experienced volunteers.

These suggestions are informed by Volunteer Canada’s Canadian Code for Volunteer Involvement (CCVI) and, in particular, its checklists for putting the Code into action (including the checklist on recruitment on page 9).  While it has not adopted the Code, we believe the CRA should heed its advice as the Code represents the industry standard for Canadian organizations, whether non profit or government, in working with volunteers.

Stagnating Volunteer Numbers: Will CRA Succeed In Recruiting Better?

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The federal government has frequently indicated it wants the CVITP to grow.  In recent years, the CVITP budget has quadrupled to expedite this growth.  As volunteers lie at the heart of the CVITP’s service delivery, the Canada Revenue Agency (CRA) needs to ramp up recruitment.  How’s that going?

In the first article of this three-part series, we explore the current trends for volunteering in Canada and in the CVITP.  We present evidence suggesting that the CVITP faces an existential threat with stagnant or declining volunteer numbers.

In the second article of this series, we review what the CRA has recently said about its plans for volunteer recruitment.  It appears to rely primarily on the volunteer recruitment efforts of its host organizations to grow its volunteer base.  Yet the evidence suggests this indirect approach, mediated via its host organizations, is not working.

Gambling further on using just this approach poses a great risk to the future success of the CVITP.  The third and final article proposes that the CRA also get directly involved in more actively recruiting volunteers.  The article offers ideas in three areas:  developing appropriate promotional materials, launching an annual recruitment campaign, and using diverse media.  These are used to illustrate what this more direct approach might look like.   The article also suggests how the CRA could manage this direct approach. 

These suggestions are informed by Volunteer Canada’s Canadian Code for Volunteer Involvement (CCVI) and, in particular, its checklists for putting the Code into action (including the checklist on recruitment on page 9).  While it has not adopted the Code, we believe the CRA should heed its advice as the Code represents the industry standard for Canadian organizations, whether non profit or government, in working with volunteers.

Once the CRA has recruited new volunteers, what can it do to keep them?  Watch for our forthcoming article on CVITP volunteer retention.

Messaging Confusion: The CRA Has More Than Just A Marketing Challenge

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The CRA markets the CVITP clinics as a place for low-income residents to get their taxes prepared.  Yet this is increasingly at odds with the experience of most of the CVITP’s clients.  They do not come to CVITP clinics to get a year-end reconciliation of the income tax they owe as their incomes are too low to pay tax.  They come because they know, from prior experience, that they can only continue to get important federal and provincial/territorial benefits if they file a return.

In this article, we explore why it matters that the CRA misrepresents the CVITP clinics in its marketing.  We recommend an alternate way of marketing the CVITP which better aligns with the reality lived by its current and potential clients.

Changing the way the CRA markets the CVITP makes it sound like it’s an isolated problem with an easy fix.  But we believe the mismatch between the CRA’s current marketing messages and the reality on the ground is indicative of a larger challenge: the CRA needs to update its vision of the CVITP.

It is no longer just a free tax preparation service.  It has also become – and arguably more importantly – a community-based service which helps low-income residents maintain their access to important poverty reducing benefits.  The evolution of the income tax and benefit system and the return preparation process it employs have driven this change.

A realistic appreciation of the two functions currently carried out by the CVITP suggests the CRA needs to embrace a different approach to its administration of the CVITP.  This new approach should emphasize the dual function throughout four stages (i.e., recruitment, training, supervision and support, recognition and retention) in the administration of the CVITP’s service delivery.  We give two examples in our article to illustrate the kind of changes this might entail.  Future articles will offer many more examples.

How To Coordinate CVITP Clinics, Why It Isn’t Happening And Why It Should

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We work as CVITP volunteers in a large urban area.  At the height of the tax season, in March and April, there are over 40 host organizations offering CVITP clinics in our area.  Yet they do not coordinate their CVITP efforts between themselves.  We suspect this is true in many urban centres.  Why?

In this article, we give nine examples to illustrate some of the ways in which CVITP host organizations can coordinate by pooling clients, volunteers and information.

We then explore the question of why this doesn’t happen more often.  In a nutshell, many host organizations feel they cannot afford the costs, in the short term, to closer collaboration.  Ideally, the CRA’s regional coordinators could take on the role of leading coordination efforts amongst host organizations within their regions, helping to overcome some of these costs.  However, given the CRA’s generally cautious approach to the CVITP, we do not see this happening anytime soon.

Yet we know that there are cases of closer collaboration between host organizations, even if infrequent.  We offer up the intriguing example of Aspire Calgary to show how 18 host organizations have managed to closely collaborate on a range of activities related to the CVITP, from training to fundraising.  Working together, they have managed to produce impressive results in support of Calgary’s poverty reduction strategy: in 2019, their 572 volunteers filed 8,797 returns in 325 clinics which generated $43 million in government benefits for people on low incomes.  We briefly outline three notable features of Aspire Calgary’s model which support this collaboration.

Such cases demonstrate that some organizations are willing to incur the short-term costs associated with better collaboration.   Why?  We believe it is because they have realized that the short-term costs are outweighed by the benefits over the medium term.  Chief amongst these benefits is better client service: more clients can be assisted; they can be assisted by volunteers who better understand their particular circumstances and the service can be offered on a more flexible basis.

Finally in our article, we set out a challenge in 2023 for host organizations who are willing to take the first step toward closer collaboration with others in their region.  We propose volunteer training, an area we find to be neglected at many host organizations we know and an important element for improving service to clients.

PM’s December 2021 Mandate Letter for Minister of National Revenue – New Priorities But No Updates on Old Priorities

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Here we go again!  Following the federal election in September 2021 and the formation of a new Liberal government, Prime Minister Trudeau issued new mandate letters to members of his cabinet, including Minister Diane Lebouthillier, the Minister for National Revenue.

What is the purpose of these mandate letters?  They publicly highlight the government’s priorities for the minister’s work portfolio.  (In the words of the PM’s website: “Mandate letters outline the objectives that each minister will work to accomplish, as well as the pressing challenges they will address in their role.”)  Ever since the Liberal Party formed a succession of governments after the federal election in the fall of 2015, Minister Lebouthillier has consistently been appointed to Cabinet as the Minister of National Revenue, overseeing the Canada Revenue Agency.

During that time, she has received four mandate letters from the Prime Minister. This has led to a proliferation of priorities: there were six priorities listed in her first mandate letter, thirteen in her December 2019 mandate letter, a further seven in her January 2021 mandate letter and now nine more in her December 2021 mandate letter.   That brings the total to 35 priorities during her six-year stint in Cabinet.  (Admittedly, there is overlap between some of the priorities.)  When there are so many priorities, arguably there are no real priorities.

Perhaps some of these 35 priorities have been added as others have, with time, been achieved by Minister Lebouthillier.  However, it is impossible to tell what progress, if any, has been made.  (For example, what became of the September 2020 pledge to develop and implement automatic tax filing that was contained in the Minister’s January 2021 Supplementary Mandate Letter?)  Although an official website was created which allowed the public to track results on the delivery of the various mandate letter priorities, updates were discontinued in June 2019. 

These two shortcomings – the proliferation of priorities and the lack of any public reports on the assessment of their implementation – raise serious questions about the purpose these letters serve beyond their value to the government as a public relations tool.

With this important context in mind, let’s look briefly at the two priorities in Minister Lebouthillier’s December 2021 Mandate Letter which are relevant to the CVITP.

1The Minister shall “continue your work to modernize the CRA to provide a seamless, empathetic and client–centric experience, including by making information easier to find and understand, accelerating the use of digital tools, and enhancing the Community Volunteer Income Tax Program.”

This is an implicit reference to one of the priorities in her Supplementary Mandate letter of January 2021, in which she was instructed to “expand and enhance the Community Volunteer Income Tax Program”.   At that time, we commented extensively on this priority here.  Only 10 months elapsed between the two mandate letters so one should not expect there to have been substantial improvements in the intervening period.  It is nevertheless somewhat gratifying to see that enhancing the CVITP remains a priority for the government.

2Furthermore, the Minister shall “develop and implement a strategy to support people filing their first income tax and benefit return, with a focus on youth and newcomers to Canada.”

While this second priority does not specifically reference the CVITP, it is likely to play a part in such a strategy given that youth and newcomers to Canada are among the clientele served by the CVITP.  This is because these two groups include many low-income residents, especially in the first year that they file their income tax and benefit return.

Collecting and Analyzing Data to Improve Service and Demonstrate Impact

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When personal information is stripped from client returns and the remaining information is aggregated, a host organization can make at least two uses of the ensuing data.  It can use the demographic and economic data to learn more about the population currently served and to improve targeting efforts in the design of future tax clinics.  The host organization can also use data on the benefits and credits generated for clients to demonstrate to its various stakeholders the impact of the current CVITP service on their clients’ financial situations.

Annually, the Canada Revenue Agency (CRA) strips the personal information from returns and provides the demographic and economic data to Statistics Canada for publication.  Infrequently, the CRA has also aggregated the data from returns on benefits and credits at the national and provincial levels and shared the figures publicly.  Given the advent of the CVITP Organization Identification Number or COIN in 2021, it is now technically feasible for the CRA to do all this for each individual host organization as well.

There are two reasons why we believe it is in the CRA’s own interest to do this.  First, by providing data to individual host organizations on the benefits and credits generated by their CVITP clinics for their clients, the CRA would be helping them to make the case to donors.  Increased donor funding would alleviate a serious resource constraint for many host organizations.  In turn, this could reduce some of the pressure on the CRA to provide funding while, at the same time, increase client access to CVITP services.

Second, by obtaining demographic and economic data on the clients served by its CVITP service, the host organization can learn more about the population currently benefiting from its CVITP service.  Where there is a mismatch between this data and the population the host organization wishes to serve, this information can be used to help better target CVITP services in the next tax season.  In turn, this could increase access to CVITP services by clients who need these the most.

In both instances, the provision of data to host organizations could help the CRA to better contribute to meeting the objectives of the federal government’s Poverty Reduction Strategy (PRS).

Quite apart from doing this to fulfill its obligation to support the government’s PRS, we believe the CRA has an obligation, as a good partner, to provide its host organizations with their data.  Currently, most host organizations offer CVITP clinics with little or no support from the CRA.  Providing this data would be one of the most important contributions the CRA could make to help its host organizations.

Although the CRA does not presently do this, some host organizations are collecting and analyzing client data from their CVITP clinics.   However, most are not.  This article explores five challenges host organizations face in doing this:

  • A lack of interest or understanding within the host organization about the importance of this data
  • Addressing client consent considerations
  • Handling client privacy issues
  • Finding staff or volunteer time to collect the data
  • Finding the expertise to analyze the data

Our experience is that host organizations mandated to promote their clients’ financial empowerment are the most successful at present in addressing these challenges.  As they already receive donor funding in support of this mandate, they are well positioned to tackle these challenges.

On the other hand, most host organizations providing CVITP services do not have clients’ financial empowerment as part of their core mandate.  Thus, they probably do not receive donor funding specifically to support their CVITP services.

One final reflection: our article addresses the use of anonymized data found in client returns.  To improve on the delivery of their CVITP services, host organizations also need to find ways to get data on non-filers within their potential client base.

The Evolution of the CVITP – 2021 Final Edition

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This is a follow up to our early edition on the evolution of the CVITP in 2021.  We consider the CRA’s annual Departmental Results Report the gold standard for CRA reporting because the report is submitted to Parliament.  Even then, data on all four elements – clients, returns, volunteers and host organizations – is hard to come by.  It is growing increasingly difficult for Parliament, the public and the host organizations and volunteers directly involved in making the CVITP a reality to know what’s happening.

In our article, we briefly discuss the numbers and their sources.  We show that the number of clients served rebounded by 43% from the spectacular low of the 2020 tax season.  (Remember: that was the season when host organizations had to stop offering in-person CVITP clinics due to the COVID health restrictions.)  Nevertheless, the number of clients served was still well below the peak achieved during the 2019 tax season.  As the CRA did not report consistently on the number of returns filed, we can only assume that it was greater than the number of clients served.  But we don’t know by how much.

Although the CRA did not report formally on the number of volunteers, we find a number in a statement by the Minister of National Revenue which suggests it declined substantially from the number reported for the 2020 tax season.  The number reported for host organizations represents a spectacular decline from the 2020 tax season.  We note that the numbers provided by the CRA for volunteers and host organizations in the 2020 tax season are misleading in that they likely included those registered with the CRA at the beginning of the season rather than those who were able to adapt to CVITP virtual clinics.  Furthermore, the 2021 figure for volunteers is simply too high to be credible.  In any event, the declines in the number of volunteers and of host organizations over the 2020 and 2021 tax seasons is deeply troubling.

Implementation of CRA’s Pilot Grant Program in Year 1 of 3 – A Slow Start to Missing the Mark

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In 2021, the Canada Revenue Agency (CRA) introduced a new pilot grant program that provides financial support to some CVITP host organizations.  When it was introduced, we had a lot to say about it here.

The pilot program has completed the first of its three years.  As is unfortunately typical of the CRA in its reporting on the CVITP, there is a dearth of information on the first year of this pilot.  However, there is one important piece of information cited in the CRA’s Departmental Plan for the 2022-23 fiscal year: “In the first year alone, the CRA sent just under one million dollars to qualifying organizations across Canada to support their efforts to ensure that vulnerable people have the ability to file tax returns and access the benefits and credits designed to support them.”

Remember: the budget for this three-year pilot grant program is $10 million; this amounts to an average of $3.3 million being available each year to support host organizations.  Disbursing less than $1 million in the first of the three years raises serious question about the ability of the pilot grant program to meet its stated objectives: defraying organizations’ costs of hosting CVITP clinics and encouraging more organizations to host CVITP clinics.

In the following article, we show that it has budgeted too much for this pilot or, on the basis of the current budget, it is simply too stingy with the current payments to meet its goals.  We predict that the pilot program will complete its three years well under budget.  There are two design elements we stated when the pilot program was first launched which are likely to contribute to this outcome: administrative arrangements that are burdensome, deterring some host organizations from applying for the grant, combined with grant amount limits that are too low to serve as an incentive for host organizations.

We note that the indicators the CRA has said it will use to determine the success of the pilot are likely to yield misleading conclusions.  This is because the implementation of the pilot program coincides with the period immediately following COVID, when the numbers for the CVITP had plummeted and thus could be expected to rebound anyways.

We also believe that the indicators the CRA is using are the wrong ones as none of them gets at the real purpose of the CVITP.  As noted in one of our articles assessing the pilot program when it was first launched, at its core the CVITP is about the income levels of the clients it serves.  Therefore, the pilot program should aim to increase the number of returns filed by a host organization for clients whose incomes fall at or below the poverty line, not simply the number of returns filed nor, for that matter, host organizations and volunteers enlisted in the CVITP.  Until the CRA draws a closer link between its CVITP and the objectives contained in the federal government’s Poverty Reduction Strategy, it will continue to miss the mark with opportunities like its pilot grant program.

Ambivalent Administrator: a Contradiction in the CRA’s Relationship with the CVITP

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Contradiction

Canadian residents with taxable income have a legal obligation to file a return.  But Canadian residents with no taxable income have no legal obligation to file a return.  What does the CRA do in the latter case, when a resident with no taxable income does not file a return and thus loses access to benefits that are contingent upon filing a return?

We believe the federal government has an expectation that the CRA will not be passive but will actively encourage residents to file.  This is because the federal government has identified so many of the benefits contingent upon filing a return as key to achieving the objectives identified in its Poverty Reduction Strategy.  And, as the federal government’s administrator of its system for filing returns, the CRA is the gatekeeper for gaining and retaining access to so many of these benefits.

The CRA’s current actions with respect to the CVITP suggest it has a highly ambivalent attitude toward the CVITP, its main program for assisting low-income residents to file their returns.  Why do we say this?

For two reasons.  First, we believe the CRA has adopted two approaches which, taken together, are contradictory.

On the one hand, the CRA has repeatedly stated the importance of maintain what it calls an arms-length relationship with CVITP host organizations (see 4 in diagram above) and their volunteers (see 5 in diagram).  For example, on page 41 of the 2020 report on the CVITP by the Taxpayers’ Ombudsman, the CRA states that it: “…strives to provide as much support as possible to the volunteers and partner organizations, while maintaining the arms-length relationship required to mitigate the liability risks that would be associated with any prescribed involvement in tax return preparation by the CRA.” 

Yet it is unclear what exactly the CRA means by an “arms-length relationship” in the CVITP context.  The CRA says it needs to maintain some distance from – or, to word it another way, not work too closely with – host organizations and their volunteers to mitigate any risks the CRA might run as a result of the returns these partners prepare for clients.

On the other hand, the CRA clearly states on its website that it is prepared to do the returns of those residents with a modest income and a simple tax situation who have used a free tax clinic before or are eligible to use one (see 1 in diagram). 

The CRA’s willingness to do the returns of low-income people and accept the risks this entails is puzzling.  It seems to contradict the CRA’s own argument about the need to mitigate for the liability risks associated with its involvement in the CVITP return preparation process by maintaining some distance from its partners.

Second, the main rationale for the CVITP is to help low-income people access benefits and credits to which they are entitled, not to pay income tax as most CVITP clients do not owe income tax.  Nevertheless, in the four years since the federal government’s publication of its Poverty Reduction Strategy (PRS), the CRA has never once publicly acknowledged the link the federal government has established between the CVITP and the PRS’s goals.

Events over the last three years should shake the CRA of its ambivalence.  Just as the CRA has seen its budget for the CVITP quadrupled with the aim of doubling its client numbers, it saw those numbers dip by a third from their peak.  If the CVITP is to be turned around, the CRA must get off the fence and take more initiative.

In the following article, we provide more details on all of this and options for the administration of the CVITP.

The Evolution of the CVITP – 2021 Early Edition

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CVITP figures for the number of people assisted this year and the number of volunteers registered show a second year of poor performance, well below its peak for the 2018 tax year (2019 tax season).  The poor performance last year was not surprising given the sudden imposition of public health restrictions due to COVID.

In the lead up to the 2021 tax season (2020 tax year), the Canada Revenue Agency (CRA) had ample time to plan for the operation of the CVITP under public health restrictions.  However, the CVITP’s performance this year was only marginally better than last year.  This is despite the CRA having been allocated in recent years a large administrative budget increase for the CVITP that was intended to double the number of people assisted.

What’s going on here?  We may never know the full story.  Earlier this year, the CRA indicated it will not be providing any information on the CVITP in its future reports to Parliament.  The timing of this decision may be purely coincidental.  But one can be forgiven for thinking that the CRA’s recent poor performance on managing the CVITP might have had something to do with it.

For further analysis with numbers and our sources, see our short article here.