Canadian government response to TEI's SBRN submission.

On June 25, 1993, Richard N. Manicom, Assistant Deputy Minister, Information Technology Branch of Revenue Canada, Customs, Excise and Taxation wrote the following letter to J. Lawrence Martin, the Institute's Vice President-Region I. Mr. Manicom's letter responds to TEI's May 25 letter on the Canadian government's proposed Single Business Registration Number initiative, which is reprinted elsewhere in this issue.

Thank you for the letter from your colleague of May 25, 1993, concerning the Single Business Registration Number (SBRN) addressed to my colleagues Messrs. Burpee and Roy. I am responding to the letter as the Revenue Canada executive responsible for the project. The thoughtful comments of knowledgeable professionals such as the Tax Executives Institute on this important issue are much appreciated. We had already noted the suggestions made at the meeting your Toronto chapter had with our regional officials on April 7, 1993. I trust that Roderick Quiney was able to shed some further light on the project during his meeting with you in Calgary on June 3, 1993.

The SBRN will allow Revenue Canada to improve the way we do business with business by changing our approach to client oriented from program centred. Use of the SBRN will permit us to reduce the compliance burden for many Canadian businesses, as well as our administrative overhead. We recognize that "one size fits all" is no longer an acceptable strategy; consequently we are considering offering businesses options from a menu, as we do for individuals with the various T1 forms. Revenue Canada has a number of service improvements underway, which will not all be of interest to all our clients. For example, most of those interested in the use of Electronic Data Interchange (EDI) are large organizations. From our consultations to date, we anticipate that an option to consolidate GST and Payroll source deductions would be of interest only to small companies. By offering a choice of "tailored" services, we can make Canada's revenue administration the most effective possible for each segment of the Canadian economy.

In order to minimize the costs to business, we have given advance notice of the transition timetable and allowed a two-year period for the conversion. Companies can convert all their accounts to SBRN at a single time of their choosing in this period. If Revenue Canada is to capture operating efficiencies, we cannot continue to run two systems indefinitely, which is why there is a deadline on the use of existing numbers of January 1997. Existing active account numbers will be replaced by SBRN account numbers on a one for one basis, so the SBRN will not affect the ability of large corporations to keep different account numbers for different locations.

In staging a restricted test of the implementation, we appreciate that there will be limitations to the conclusions we can draw. Our aim is to maximize the benefits while minimizing the consequences of any problems which the test uncovers. The majority of our clients are small or medium sized enterprises operating in single cities. The current test should reveal any problems that most of our clients would encounter and allow us to plan the national launch more effectively. An approach which involved large organizations operating in many different areas outside the test cities would require that we trained the staff in all our offices for 1994; otherwise any problems might be the result of operating partly in a fully prepared market and partly outside. In order to address any basic problems with conversion to SBRN, we will include existing companies by soliciting volunteers in the test areas. We will conduct a thorough evaluation of all aspects of the test, including seeking the views of our field office employees and the organizations that participate.

We are currently developing a model for handling inquiries once SBRN is in place. An "account officer" for each client is an interesting idea and one of the options we are considering. Our plan for the test includes thoroughly evaluating the inquiries function during 1994 before the national launch.

We recognize that there is one area of special concern to large organizations: the conversion process. Obviously we cannot expect to spend hours on the telephone with each large company exchanging account numbers, nor do we wish to introduce further errors in the system by keying large volumes of account numbers. We would be interested in discussing any suggestions you may have that would allow us to perform this conversion efficiently for large organizations, while respecting the requirements of security and privacy.