New Head Of The Cra Has Her Work Cut Out For Her

Neil Armstrong stepped off the ladder of the lunar module on July 20, 1969, and into history: “That’s one small step for man, one giant leap for mankind.”

Armstrong long maintained he said “for a man” and the “a” was lost in transmission, but that line came to mind when Prime Minister Mark Carney announced last month that Heather Evans would become the next commissioner of revenue on July 13, just a week before the moon landing’s 57th anniversary.

Evans has led the Canadian Tax Foundation since 2016 and was previously national managing partner of tax for a Big Four professional services firm. I have known Evans from my years in foundation leadership, including as its chair before her tenure, and I hold her in high regard.

Revenue Canada, formerly a government department, was converted into the Canada Revenue Agency in 1999, freed from the Treasury Board’s grip and given its own board of management precisely to import private-sector discipline.

The org chart changed, but the instincts never did and every commissioner came from within the government. Evans, though, arrives directly from the private tax community. The Union of Taxation Employees is “ cautiously optimistic .” So am I, but for different reasons.

The CRA has a vitally important and very difficult job administering the Income Tax Act and numerous other statutes. However it administers the law; it does not write it. Within the commissioner’s administrative authority, though, lie meaningful small steps and Canadians should insist they be real ones.

Real ones? We’ve just lived through the alternative. Last September, after Finance Minister François-Philippe Champagne declared the CRA’s service delays “ unacceptable ,” the agency launched a 100-Day Plan . In late October, the auditor general released a scathing report on the agency’s call centres, and the plan’s true origin became obvious: the government had the report in advance and was managing the damage.

After day 100 arrived on Dec. 11, the results were what I predicted : bureaucratic and political self-congratulation. The 100-Day Plan wasn’t one small step; it was a moonwalk, a performance of motion, with the root causes left exactly where they were.

To be fair, some say the plan produced real improvements and was the kick in the pants the CRA needed. Perhaps. But practitioners have documented many of the CRA’s issues for years with no meaningful response.

If it took an auditor general’s report — and a minister’s political need to get ahead of it — to finally administer the kick, that is not a defence of the plan; it is an indictment of the culture, one that responds to headlines, but not to Canadians and their advisers who deal with it daily.

Culture is where the new commissioner’s real small steps lie. Evans’ first test arrives immediately: the government in February announced that public servants must work onsite four days a week. The CRA will implement the change in late July, unevenly.

That lands two weeks after Evans takes office, with the same “cautiously optimistic” union having filed unfair labour practice complaints. I encourage Evans to see this through. Tax, including its administration, is a craft best learned shoulder-to-shoulder, not transmitted through a screen.

Next, change how the CRA listens. Formal consultations with CPA Canada, the Canadian Tax Foundation and the Canadian Bar Association are valuable, but polite and filtered through organizational diplomacy. I’d encourage the establishment of a standing advisory committee of individual practitioners from across Canada to hear, unfiltered, what is actually happening on the ground.

Pair that with genuine two-way secondments — Interchange Canada exists for exactly this — and the 1999 promise of an agency with private-sector discipline might finally mean something.

Another small step would be to publish an updated formal policy on administering proposed, but not legislated tax measures. The 2024 capital gains debacle — taxpayers pushed to file, pay and plan on a proposal that ultimately died — was the worst example.

Administration should only begin once a bill is tabled, sunset automatically if legislation stalls and carry automatic interest and penalty relief when proposals die or materially change. No one is better positioned to champion this than a commissioner who watched the wreckage from the receiving end.

These are small steps. The giant leap, comprehensive tax review and reform , is beyond any commissioner’s reach.

The first and only comprehensive review of Canada’s tax system was the Royal Commission on Taxation , which released its report in 1966, leading to significant reforms in 1972. There has been some tinkering since, but tinkering is not reform and only Parliament can deliver it.

Still, a commissioner is not voiceless: she can improve the administrative application of the law and formally recommend improvements to the finance minister. A commissioner from the trenches saying exactly that would be worth a dozen 100-day plans.

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One caution: excellent tax credentials do not automatically make for an excellent leader of one of the government’s largest organizations. Moving from a Big Four firm to leading a small, but influential foundation and more than 50,000 employees is a different order of challenge given the stakeholders: the public, her employees, practitioners, academics, the justice community from the Tax Court to the Supreme Court, international peers and her political bosses.

But the foundation job is an exercise in balancing competing constituencies and Evans has done it with distinction. Few outsiders arrive better prepared.

Armstrong’s small step only mattered because of the giant leap it represented. Evans takes her own first step on July 13. If her steps are real ones, measured in outcomes rather than press releases, and if the government supplies the reform ambition that only Parliament can, then one small step for the CRA might yet become a giant leap for taxpayers : a better tax system for the benefit of all Canadians.

This time, let’s lose nothing in transmission.

Kim Moody, FCPA, FCA, TEP, is the founder of Moodys Tax/Moodys Private Client, a former chair of the Canadian Tax Foundation, former chair of the Society of Estate Practitioners (Canada) and has held many other leadership positions in the Canadian tax community. He can be reached at kgcm@kimgcmoody.com and his LinkedIn profile is https://www.linkedin.com/in/kimgcmoody.

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