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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.
Disclaimer:
Eileen Reppenhagen CGA does
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