THE TRANSFER OF TAX POINTS
UNDER THE CANADA HEALTH AND SOCIAL TRANSFER
TABLE OF CONTENTS
THE CALCULATION OF TAX TRANSFERS
A. Federal Income Tax Rate
B. Basic Federal Tax and
Provincial Tax Base
C. Provincial Income Tax Rates
EVOLUTION OF CASH AND TAX
TRANSFERS UNDER THE CHST
THE TRANSFER OF TAX POINTS TO
UNDER THE CANADA HEALTH AND SOCIAL TRANSFER
The federal government provides transfer
payments under the Canada Health and Social Transfer (CHST) to help the provinces carry
out their responsibilities with respect to health, post-secondary education and social
assistance. The CHST consists of a cash transfer and a transfer of tax points. There is a
dichotomy between the views of the federal government and those of the provinces
concerning the tax transfer. For the federal government, the transfer of tax points is a
means of transferring fiscal resources to the provinces to help them with their
expenditure responsibilities in designated areas. By contrast, the provinces consider that
only the cash transfer is a federal contribution.
Tax points transferred to the provinces
are certainly the most complicated aspect of federal-provincial fiscal arrangements. The
context in which tax transfers were instituted and how they are evaluated may help to
explain them. This paper provides a definition of tax transfers, reviews their history,
explains how they are calculated, provides comparative statistics on the evolution of CHST
cash and tax transfers and highlights some of the issues related to tax points.
A tax point is a permanent transfer of
income tax room from the federal government to the provincial governments. The federal
government reduces its basic tax rate by a specific percentage and the provinces increase
theirs by an equivalent amount, thereby leaving total federal and provincial tax
unaffected. Tax points can be applied to personal income tax (PIT) or to corporate income
A tax point or tax room can also be
defined as the fiscal compensation offered by the federal government to replace a federal
cash contribution. When it negotiated fiscal arrangements, the federal government
generally offered the provinces the opportunity to "opt-out" of a program and to
receive some substitute for the federal contribution to such a program in the form of tax
A transfer of tax points is different from
a tax abatement, although the latter is also a form of compensation in lieu of cash
contribution. A tax abatement is a special deduction after the basic federal tax(1) has been determined; tax points directly reduce the
federal income tax rate. Moreover, a tax abatement is not permanent and can therefore be
recovered: if the total transfers to which a province is entitled are less than the value
of the tax abatement, the federal government must recover the difference through either a
reduction in other federal cash transfers or repayment by the provincial government.
Similarly, if a federal program of cash contribution is cancelled, the opting-out
provinces must reimburse the value of the tax abatement either directly or through a
reduction in other cash transfers. Tax points transferred to the provinces and tax
abatements do have the same outcome, however: they reduce federal revenues from income
tax. As we will see in the following section, tax abatements led the way to formal tax
transfers in fiscal arrangements between the federal and provincial governments.
Tax transfers and tax abatements have long
been an important part of federal-provincial fiscal relations. The first transfer of tax
points between the federal government and the provinces was in 1941 during the Second
World War. In contrast to current tax points, however, this transfer went from the
provinces to the federal government. More specifically, from 1941 to 1962, the federal
government "rented" all the taxation powers of the provinces.(3) This centralization of taxation powers enabled the federal government
to deal with the increase in war and military spending and then to finance expenditures in
the post-war period. In return for giving up their right to levy taxes, the provinces
received a cash contribution calculated on a per capita basis (from 1941 to 1957) or as a
percentage of personal and corporate income tax revenues collected by the federal
government within their jurisdictions (from 1957 to 1962).
Although Quebec signed the 1941 rental
agreement, it refused to be party to the others (1946, 1952 and 1957). Instead, the
province requested and received tax abatements. All other provinces maintained the renting
agreements.(4) In 1947, Quebec introduced its own
corporate income tax (CIT) and was granted a federal abatement of 7 points on that tax.
When, in 1954, Quebec introduced its personal income tax (PIT), the federal government
provided an opting-out allowance of 10 PIT points. In 1958, the abatement for Quebec as a
non-participating province was increased to 13 PIT points and to 9 CIT points. Overall, it
can be said that the Quebec arrangements were in a broad sense precursors of the
subsequent federal-provincial agreements as they incorporated the idea of a cash-tax
In 1962, the system of tax rentals was
replaced by a tax collection agreement under which the federal government collected income
taxes on behalf of the provinces, each of which was given the flexibility to set its own
income tax rate. All provinces except Quebec accepted the federal government offer to
collect tax from PIT (which allowed a single tax form for personal income).(5) Three provinces, Quebec, Ontario and Alberta, did not
participate in the tax collection agreement for the corporate income tax. A tax abatement
of 16 points was provided on personal taxable income (which meant an additional 3 PIT
points for Quebec), while the CIT abatement was fixed at 9 points. Therefore, under the
new tax agreement the participating provinces had the same tax room as Quebec. These
arrangements also provided that the federal government would gradually increase tax
abatements to the provinces: by 1966, the abatement had reached 24 PIT points.
During the 1960s, the federal government
began to contribute funding for specific programs, and, in compensation for its
non-participation, Quebec requested an increase in tax abatements.(6) For example, in 1960, Quebec was granted an additional abatement point
of the CIT in lieu of a specific transfer to universities. Similarly, in 1964, it was
offered a further abatement of 3 PIT points for the Youth Allowance Program.(7) In 1965, the federal government offered the provinces 15
PIT points in lieu of cash transfers under various arrangements in the areas of health and
vocational training; only Quebec accepted the federal offer. Arrangements were also made
to permit opting out of the Canada Assistance Plan (CAP) which was established in 1966.
For all provinces except Quebec, CAP involved cash transfers only. As part of the
opting-out agreements, Quebec received a 5-point tax abatement on personal income. As a
result of these opting-out provisions, Quebec was receiving, by the end of 1966, 23
additional PIT points and 1 CIT point over and above the tax abatements of the other
In 1967, the federal government began
providing all provinces with a special abatement on both the personal and corporate income
taxes in lieu of post-secondary education transfers. More specifically, the provinces were
granted 4 additional PIT points and one CIT point (the point previously received only by
Quebec). For all provinces except Quebec, this change increased the abatement in PIT from
24 to 28 and in CIT from 9 to 10. Also in 1967, the tax abatement for vocational training
(1 PIT point) was withdrawn, thereby reducing Quebecs special abatement to 22
points, (overall, Quebec was now receiving 50 PIT points and 10 CIT points).
Following the 1972-1977 tax agreement, the
general abatement system was abandoned (except for the additional 22 abatement points
Quebec received under the opting-out agreements) and replaced by true tax point transfers.
What was previously shown as an itemized reduction in PIT on federal tax forms was
translated into a reduction in federal tax rates. More specifically, federal tax rates
were reduced by 30.5% of the basic federal tax (this reduction was estimated to be
equivalent to the former tax abatement of 28 points). This 30.5% reduction replaced all
former tax abatements, including the abatement received in lieu of cash transfers for
education in 1967; the 4 PIT abatement points for this purpose were transformed into 4.357
PIT tax points in order to preserve the value of the transfer. Further, the provinces were
free to impose whatever tax rate they desired; provincial tax rates were expressed as a
percentage of basic federal tax and could be more or less than 30.5%. The abatement system
for CIT was retained at 10 points. For Quebec, the PIT points it had received as a result
of the former opting-out arrangements were adjusted from 22 to 24.
In 1974, the Youth Allowance Program was
dismantled and replaced by the Family Allowances plan, in which all provinces agreed to
participate. Thus, the opting-out provision no longer applied to Quebec and the 3 PIT
points abatement earmarked for that program had to be recovered. To avoid disrupting
Quebecs tax structure, the 3 point abatement was continued, but the amount was, and
still is, fully deducted from federal cash payments to the province.
The last transfer of tax points took place
in 1977, when a new formula for financing the so-called "established" programs
hospital insurance, medical care and post-secondary education was adopted.
Established Programs Financing (EPF) involved both a cash and a tax component. With
respect to tax points, the federal government transferred to the provinces a total of 13.5
points of PIT and one point of CIT. Since the tax point transfers already included the
4.357 points of PIT and the one point of CIT given to the provinces in 1967 for
post-secondary education, the new tax room was actually 9.143 points of PIT. The abatement
points previously granted Quebec under the opting-out agreements for the purpose of health
were readjusted to 8.5 PIT points.(8)
Since 1996-1997, transfers provided under
EPF and CAP have been combined in the Canada Health and Social Transfer (CHST). However,
this change in legislation had no effects on the level of tax transfers. Consequently, tax
points provided under the CHST still amount to 13.5 points of PIT and one point of CIT,
with the same level of additional tax abatements for Quebec (that is 8.5 PIT points under
EPF and 5 PIT points under CAP).(9)
CALCULATION OF TAX TRANSFERS
This section explains how tax transfers
are calculated and examines their impact on individual taxpayers. These transfers are
intended to make no difference in the amount of combined federal and provincial tax paid
by the taxpayer.
Tax transfers received by a province are
based on the estimated value of past reductions in federal income taxes whereby that
province was given room to increase its own income tax revenues. The transfer of tax
points has three intertwined outcomes: first, it decreases the federal income tax rate;
second, and as a result of the tax reduction, it reduces the basic federal tax (which, in
turn, directly reduces the provincial tax base); and third, a province must increase its
own income tax rates in order to generate additional revenue equivalent to the decrease in
federal income. The following information is based on an example illustrated in Table 1.
EXAMPLE OF A TAX POINT TRANSFER
Provincial Tax Rate
Nota: For an
interesting and complete numerical example of the impact of a tax point transfer, see
Treasurer of Ontario, Ontario Budget 1977, Budget Paper B, 19 April 1977,
Income Tax Rate
With respect to PIT, the CHST is
currently made up of 13.5 tax points which were part of the former EPF program. When EPF
was established, however, 4.357 points had already been transferred, so that the federal
government actually reduced its tax rate by 9.143%, rather than 13.5%. The taxpayer who
paid $1,000 of federal income tax before the transfer of tax points paid only $908.57
($1,000-$91.43) once the transfer had taken place.
B. Basic Federal Tax and Provincial
The reduction in the federal income tax
rate translated into a decrease in basic federal tax. Since the base on which the
provinces (except Quebec) levy their personal income taxes is the basic federal tax
itself, the smaller basic federal tax led to a reduction in the provincial tax bases. To
pursue the previous example, a province had to apply its own tax rate on $1,000 before the
transfer of tax points but on only $908.57, in the post-transfer period.
Provincial Income Tax Rates
A reduction in the tax base of the
provinces had two implications for their tax rates. With a smaller tax base, provinces
needed to raise their rates in order, first, to maintain the level of revenue received
under the pre-transfer system and, second, to take full advantage of the vacated tax room,
while at the same ensuring that the taxpayer was not affected. In our example, let us
assume that the provincial tax rate on personal income was 30.5% of the basic federal tax
before the transfer of tax points. In the pre-transfer period, the taxpayer paying $1,000
in federal income tax paid $305 in provincial income tax, for a total of $1,305. When
transferred tax points are taken into account, the provincial tax rate could go from 30.5%
to 43.6% without affecting the taxpayer.
Table 2 shows provincial income tax rates
before the transfer of tax points in 1976 and after the transfer of tax points for both
1977 and 1996. The "Equivalent" column provides the tax rate allowing the
province to capture the full impact of the tax point transfer. As can be seen, all
provinces increased their rate to occupy the new tax room. Two provinces, Newfoundland and
Saskatchewan, raised their rates beyond the level necessary to fill the new tax room. Over
the years, many provincial PIT rates have increased substantially, possibly to offset the
limits placed on the growth rate of federal transfer payments.
PROVINCIAL INCOME TAX RATES (QUEBEC EXCEPTED)
Prince Edward Island
Source: For the
first, second and third columns see George E. Carter, "Financing Health and
Post-Secondary Education: A New and Complex Fiscal Arrangement", in Canadian Tax
Journal, Sept.-Oct. 1977, Vol. 25, No. 5, p. 542; the fourth column is from KPMG
International website under TaxFacts - Canada.
For purposes of the CHST, the value of tax
points transferred to the provinces is calculated in terms of the lower basic federal tax.
As already noted, the federal government gave up 13.5 PIT points, which, expressed as a
percentage of the new base, become 14.85851 PIT points or 13.5/(1-0.09143). This is the
rate used to calculate tax points to the provinces under both EPF and the CHST.(10) Once the value of tax points has been determined, the
formal equalization formula is applied.
For the fiscal year 1996-97, the
Department of Finance estimated that revenues from PIT and CIT in Canada would amount to
$69.4 billion and $64.7 billion respectively. The value of tax transfers under CHST would
therefore be $11.8 billion, or (69.4*0.1485851) +(64.7*0.01)+0.8 billion in associated
equalization.(11) The value of equalized tax point
transfers are then deducted from the total transfers to which the provinces are entitled
and the difference is given in cash transfer.(12)
Because it represents a fixed percentage
of federal taxation, the value of tax transfers fluctuates with the variation in federal
income tax revenues. In a period of economic growth, when government tax revenues are
expected to increase, the value of tax points will increase also. Conversely, poor
economic growth reduces federal government tax revenues, resulting in a lower value of tax
point transfers. In the same way, any expansion (reduction) of the federal income tax base
or increase (decrease) in federal tax rates would increase (decrease) the value of tax
EVOLUTION OF CASH AND TAX
TRANSFERS UNDER THE CHST
Table 3 provides details of cash and tax
transfers to the provinces under the CHST. The Federal-Provincial Fiscal Arrangements
Act determines the total amount of CHST: it is set at $26.9 billion for 1996-97
and $25.1 billion for the period from 1997-98 to 1999-2000. Thereafter, and until 2002-03,
the total CHST transfer will be adjusted according to a percentage of the rate of growth
in the GDP. As a result of this legislation, total CHST transfers will decrease sharply;
from 1995-96 to 1996-97, they fell by nearly $3 billion and the reduction will amount to
$4.5 billion between 1995-96 and 1999-00.
The value of CHST tax points transferred
to the provinces, which varies in proportion to income tax revenues, is expected to
increase constantly from 1996-97 to 2002-03. As a result, the cash transfer, which
represents the difference between the total CHST transfer and the value of tax points, is
expected to decrease steadily until 2000-01. Cash transfers will decline more steeply than
total transfers. Beginning in 1997-98, the total CHST transfer will be almost evenly
divided between tax points and cash transfers; thereafter, the value of tax points will
exceed the amount of the cash transfer.
CASH AND TAX TRANSFERS UNDER THE CHST
(in millions of dollars)
Nota: Data for
1995-96 correspond to the sum of transfers under EPF and CAP.
Source: Department of Finance, Human
Resources Development Canada and Parliamentary Research Branch, Library of Parliament.
In short, the effect of the decrease in
total transfers under the CHST will be entirely seen in the cash transfer, whereas the
gradual increase in the total transfer, beginning in 2000-01, will basically result from
the increased value of the tax points.
The value of tax points is growing to
represent an increased proportion of total federal transfer payments to the provinces.
Whether the transfer of tax points really constitutes a federal contribution is subject to
debate. The provinces regard the tax points as a one-time permanent transfer, while the
federal government continues to count them as an ongoing contribution to provincial
The federal government argues that the
growing value of the tax points transferred is part of the original fiscal arrangements
and, as a result, must be considered an integral part of federal transfers. It also states
that "cash and tax transfers are alike in that both represent a cost to the federal
treasury and both contribute to provincial revenues."(13)
Similarly, some analysts claim that "it was understood at the beginning that the
income tax point values would eventually grow faster than total transfer payments and that
the cash portion would gradually decrease over time."(14)
They also maintain that "[w]hile declining cash may be an irritant to some provinces,
it results from the correct operation of the formula embedded in the EPF and CHST
calculation, and not from any federal policy withdrawal."(15) It must be acknowledged, however, that cash transfers have decreased
faster than originally expected, as a result of unilateral changes by the federal
By contrast, other experts believe that
the federal government claim to be giving the provinces this tax revenue is "pure
rhetoric" since the actual collection is left to the provinces themselves. In this
view, the tax points turned over to the provinces are now the provinces own source
revenues, over which they have full discretion.(16)
Others suggest that to consider the transfer of tax points as part of the federal transfer
may result in "misleading interpretations": first, it would allow the federal
government to overstate the federal contribution to the provinces for the support of
post-secondary education, health and social programs and, second, it would allow the
federal government to understate the percentage change in the size of federal cutbacks to
the provinces.(17) Still, other experts view the tax
transfer only as a "notional" transfer used for calculating the CHST, since
there is actually no money directly involved. They also maintain that, since the
concession of the tax room was intended as compensation for withdrawn federal grants, only
the cash transfer has retained a federal identity.(18)
It is interesting to note that 20 years ago it was already being argued that "once
the size of the equalized tax points comes to exceed that of the cash grant in all
provinces, the association the tax transfer now has with a specific area of provincial
expenditure will vanish."(19)
Recently, there was a proposal to transfer
more tax points to the provinces. This would reduce the basic federal tax and limit its
power to impose national standards in the area of health or to set other conditions for
social programs. Moreover, the federal government has stated that it could not afford to
provide more tax room and still meet its deficit targets.(20)
A larger tax transfer would give greater flexibility to the provinces, who would thus have
more room to manoeuvre with respect to the organization and delivery of health care and
social services. More tax points would also shelter the provinces from unilateral federal
budget cuts. Relying on more tax room as a means of transferring funds to the provinces
could, however, eventually give the provinces complete freedom to set their own rates and
bases and thus give rise to fragmentation of the uniform tax bases. Further, since tax
points are less valuable in the poorer provinces, such provinces could have difficulty in
maintaining their current level of services. More tax room could remove the redistributive
element involved in federal-provincial fiscal arrangements.
Thomas J. Courchene has suggested that tax
points be entirely removed from the CHST calculation and that only an equal per capita
cash contribution be transferred to the provinces.(21)
In his view, this approach would ensure both that cash transfers did not fall to zero,
thereby preserving the federal governments role in establishing and maintaining
national standards, and that provincial government could rely on a steady contribution.
This suggestion could be implemented only if the federal government agreed to forget
completely the cost it incurred when it first transferred tax points to the provinces.
Through the CHST, the federal government
provides both cash and tax transfers to the provinces. Tax transfers are not new under the
CHST. Indeed, federal contribution programs combining a cash and tax component have a long
history in Canada. The transfer of tax points is an important component of
federal-provincial fiscal arrangements. The calculation of the value of tax points is
rather complex but the major characteristic of a tax transfer is its neutrality in terms
of its impact on an individual taxpayer. The purpose of a transfer of tax points is to
provide provinces with more tax room by reducing federal income tax rate and allowing the
provinces to make a corresponding increase in the tax revenue they collect. The federal
government believes that the resulting reduction in its revenue must be estimated and
taken into account when calculating the amount of CHST transfer payments. The provinces,
by contrast, view the tax transfers as part of their own revenues and regard only the cash
transfer as a federal contribution.
Under the CHST, the values of cash and tax
transfers ($12.5 and $12.6 billion respectively) are almost equal; however, it is expected
that the value of tax points will soon be greater. It may become increasingly difficult
for the federal government to reflect its true financial commitment to health,
post-secondary and social assistance with a relatively smaller cash contribution.
Banting, Keith and Boadway, Robin. Presentation
to the Standing Committee on Finance. 9 May 1995, 7 p.
Boadway, Robin. The Canada Health and
Social Transfer. Brief to the House of Commons Standing Committee on Finance. 1995, 7
Boadway, Robin W. Intergovernmental
Transfers in Canada. Canadian Tax Foundation, 1980, 93 p.
Boothe, Paul and Johnston, Barbara.
"Stealing the Emperors Clothes: Deficit Offloading and National Standards in
Health Care." Commentary, C.D. Howe Institute, No. 41, March 1993, 12 p.
Canada, Department of Finance,
Federal-Provincial Relations Division. Canada Health and Social Transfer, Second
Estimate: 1996-97. Government of Canada, 9 October 1996.
Canada, Department of Finance. Briefing
Book: Budget 1996. 6 March, 1996, p. 49-67.
Canada, Department of Finance. Federal
Transfers to Provinces. May 1990.
Carter, George E. "Established
Programs Financing: A Critical Review of the Record." In Canadian Tax Journal,
Vol. 36, No. 5, September-October 1988, p. 1225-1243.
Carter, George E., "Financing Health
and Post-Secondary Education: A New and Complex Fiscal Arrangement." In Canadian
Tax Journal, Vol. 25, No. 5, September-October 1977, pp. 534-550.
Courchene, Thomas J. Redistributing
Money and Power- A Guide to the Canada Health and Social Transfer. Observation 39.
C.D. Howe Institute, Toronto, 1995, 122 p.
Courchene, Thomas J. Social Canada in
the Millennium - Reform Imperatives and Restructuring Principles. C.D. Howe Institute,
1994, 368 p.
Hobson, Paul A.R. and St-Hilaire, France. Reforming
Federal-Provincial Fiscal Arrangements - Towards Sustainable Federalism. Institute for
Research on Social Policy, Montreal, 1993, 82 p.
KPMG international website under TaxFacts
Robinson, T. Russell. "Canadian
Fiscal Arrangements in the 1990s: A Federalists Perspective." Policy Options,
Vol. 14, December 1993, p. 49-53.
Strick, J.C. Chapter 7:
"Federal\Provincial Fiscal Relations: Historical Development." In Canadian
Public Finance - Fourth Edition, Toronto, 1992, pp. 148-168.
Treasurer of Ontario. Ontario Budget
1977. Budget Paper B. 19 April, 1977, 20 p.
basic federal tax corresponds to the revenue raised by the federal government through
income tax. The tax abatement appears in the federal tax form as a specified reduction
(expressed as a percentage of federal taxes owing).
section is based on information from the following documents: T.J. Courchene,
"Historical Annex on the Quebec Abatement," in Redistributing Money and Power
A Guide to the Canada Health and Social Transfer, Observation 39, C.D. Howe
Institute, Toronto, 1995; P.A.R. Hobson and F. St-Hilaire, Chapter 3, "EPF and the
Devolution of Tax Room," in Reforming Federal-Provincial Fiscal Arrangements -
Towards Sustainable Federalism, Institute for Research on Social Policy, Montreal,
1993; J.C. Strick, Chapter 7: "Federal/Provincial Fiscal Relations: Historical
Development," in Canadian Public Finance - Fourth Edition, Toronto, 1992;
Robin W. Boadway, Chapter 2, "The Existing Structure of Intergovernmental Transfers
in Canada," in Intergovernmental Transfers in Canada, Canadian Tax Foundation,
1980, p. 4-40.
1940, all provinces were taxing both personal and corporate income.
According to Strick, "renting was politically attractive for provinces since it
allowed them to enjoy the revenues from unpopular taxes yet not be responsible for
imposing them." In Canadian Public Finance - Fourth Edition (1992), p.
system of tax collection is currently still in use. Under the agreement, provincial tax
bases, except that of Quebec, correspond to the basic federal tax.
Quebec has always argued that by making specific-purpose transfers the federal government
is interfering with matters of essentially provincial responsibility.
Quebec already had a similar program and wished to continue it. The federal government
agreed to allow the province to receive the federal contribution in the form of additional
abatement points rather than as a specific cash transfer.
other abatements provided to Quebec, namely the tax abatement of 5 PIT points for CAP and
the 3 PIT points for the youth allowance, remained unchanged.
total 16.5 special PIT tax abatements provided to Quebec 8.5 points under EPF, 5
points under CAP and 3 points under the Youth Allowance Program - appear in the federal
tax form for Quebec taxpayers as a specified reduction of 16.5% of federal taxes owing.
See Federal-Provincial Relations Division, Department of Finance, Canada Health and
Social Transfer, Second Estimate: 1996-97, Government of Canada, 9 October 1996.
The equalized tax point transfers under the CHST do not reflect the current value of these
tax points to provinces; rather, they measure the current cost of this transfer to the
Department of Finance, Federal Transfers to Provinces, Government of Canada, May
1990, p. 2.
See for example, T. Russell Robinson, "Canadian Fiscal Arrangements in the 1990s: A
Federalists Perspective," Policy Options, Vol. 14, December 1993, p. 51.
Boothe and B. Johnston, "Stealing the Emperors Clothes: Deficit Offloading and
National Standards in Health Care," Commentary, C.D. Howe Institute, No. 41,
March 1993, p. 4; Keith Banting and Robin Boadway, Presentation to the Standing
Committee on Finance, 9 May 1995, p. 4.
Robin Boadway, The Canada Health and Social Transfer, Brief to the House of Commons
Standing Committee on Finance, 1995, p. 3.
George E. Carter, "Established Programs Financing: A Critical Review of the
Record," Vol. 36, No. 5, Canadian Tax Journal, September-October 1988;
Thomas J. Courchene, Social Canada in the Millennium - Reform Imperatives and
Restructuring Principles, C.D. Howe Institute, 1994, p. 112-115.
George E. Carter, "Financing Health and Post-Secondary Education: A New and Complex
Fiscal Arrangement," in Canadian Tax Journal, Vol. 25, No. 5,
September-October 1977, p. 547.
Canada, Department of Finance, Briefing Book: Budget 1996, 6 March 1996, p. 65.
Courchene (1994), p. 102-103.