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Response to Dec 15, 2025 Technical Advisory Report

March 3, 2026

-----Original Message-----
From: Carol Stinson [mailto:]
Sent: February 28, 2026 1:17 PM
To: 'Eileen Reppenhagen, CGA'
Subject: RE: Disability is Natural Newsletter & Tax
response article


Thanks Eileen, I used to be subscribed to this newsletter
but forgot to "re-enlist" when we changed the email
addresses here at SFSCL.
By the way, I wanted to send you the article I wrote for
the CPABC newsletter.
I've reproduced it below:
-------------------------------------------------------------------------------------------------------------
Article - Tax Response

On December 15, 2004, the Technical Advisory
Committee on Tax Measures for Persons with Disabilities
released its report “Disability Tax Fairness”. The report
is available on the web at www.disabilitytax.ca (the full
report is very lengthy so you may want to read only the
summary of recommendations).

As the Treasurer of the CPABC, I am encouraged
that the Federal Government is trying to address issues of
inequity in the existing tax system and unmet
disability-related costs for persons with disabilities,
their families and caregivers.

Many of the recommendations are “housekeeping” measures to
improve communication between the Canada Revenue Agency
(CRA) and Canadians regarding legitimate disability
measures - but some are more positive. Some of these are:

Ø to increase flexibility in RESP rules for students
with disabilities.

Ø to review of RRSP/RRIF rules to allow more
flexibility for the use of funds left to a child or a
grandchild with a disability. For example, allowing a roll-
over into a discretionary trust;

Ø to expand disability supports for education and
employment purposes by recognizing more expenses as
legitimate deductions. For example, note takers or
voice-operated software could be deductible;

Ø to increase the Child Disability Benefit by $600
to a maximum or $2,253 and this amount be indexed to the
cost of living;

Ø to increase the refundable medical expense
supplement from a maximum of $562 to $1,000 - to be
indexed;

Ø to increase the limit of expenses under the
medical expense tax credit by caregivers from $5,000 to
$10,000.



I also have a few concerns regarding the report. These
include:

a) The recommendation that CRA review the expenses
being claimed under the medical expense tax credit and
consider the appropriateness of these claims. Parents in
the CP Community have particular problems with covered
expenses for children. Often new therapies are tried on
children because there is a possibility of improvement.
Parents pay for these therapies because they will pay or do
anything to help their children. The CRA is slow to
recognize new therapies, whether they work or not, and seem
to take a zealot’s approach to refusing claims. Our family
has been audited twice by CRA for medical expenses for our
daughter and most families I know have similar CRA
harassment stories.

b) Regarding the Child Disability Benefit, the
committee decided not to extend it to middle income
families because of “fiscal constraints”. The committee
confirms that the benefit does not mirror the income range
for the typical child tax benefit but it would cost too
much. It is the children of middle income parents who
will not benefit much from the changes to the RRSP/RRIF and
RESP rules and this further reduces their chances of
benefit.

c) The discussion regarding caregivers is pretty blunt
about the tax system’s ability to offer support: “The
function of the tax system is to recognize extra costs
incurred by Canadians … that reduce their ability to pay
tax. It is not to compensate or reimburse individuals for
expenses they incur or for foregone income” (pg 65). The
disability community has to recognize that the scope of
these recommendations are quite narrow – and why.

d) In their conclusion, the committee recognized that
many issues, while outside of their mandate, had a great
impact upon the cost of disability to individuals and
society. For example, the total system of benefits needs
to be better coordinated so that one benefit doesn’t reduce
another benefit. This problem is recognized in the report
but no leadership role is recommended

e) The committee recommends spending more money in the
future on “programs…to target new funding where need is
greatest” (pg 81). As the parent of a child with CP I have
concerns about dollars which don’t seem to reach the people
for whom they are intended. Money must be put into the
hands of individuals, or their caregivers, to spend where
they perceive their need is greatest and the tax system can
work to do this.



I would have liked to have seen more dynamic
language and suggestions in the committee’s recommendations
in their concluding chapter, Future Directions. There are
some interesting musings on a social model framework of
disability (pg82) and the committee notes that the
disability community needs the resources to participate in
public consultation and debate. For example, the CPABC
has a great deal of trouble finding the financial resources
to advocate for or represent persons with CP at local,
provincial or federal tables. “Funders” fund services, not
advocacy. The committee recognizes that young persons with
disabilities living in poverty face different challenges
than seniors with acquired disabilities who have had a
life-time to accumulate assets and who, therefore benefit
fare more from tax-reduction measures. But the committee’s
recommendation of money for programs will not solve the
problem of poverty without leadership to guide all levels
of government in coordinating benefits.



In conclusion, we can hope that the recommendations in this
report will be considered favourably by parliament and
maybe even expanded upon to include middle-income families.
These recommendations are a piece of a vision for the
future for a better, more secure life for ourselves and our
loved-ones who live with a disability. It lies with the
disability community to continue to bring our concerns to
the attention of parliament.

 

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