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CCA Advocates for Federal Tax Changes

The Honourable William Francis Morneau, PC, MP

Minister of Finance
House of Commons
Ottawa, Ontario   K1A 0A6

Dear Minister,

The Canadian Celiac Association is the national voice for the over 350,000 Canadians who suffer from celiac disease, an autoimmune condition for which there is no cure and which can be life threatening if not properly treated. For us, following a strict gluten-free diet for life is an absolute necessity to prevent complications such as osteoporosis, malnutrition, and intestinal cancer.

Unfortunately, a gluten-free diet is not so straightforward. In addition to the difficulty in finding products free of any cross contamination, peer-reviewed research[1] has shown that the cost of gluten-free food is approximately 242% that of “regular” foods. For example, while a loaf of bread can be found for $1.99 in many parts of Canada, gluten-free breads typically retail for around $6.99 per loaf.

A diagnosis of celiac disease, and the requirement of a strict gluten-free diet, has been shown to cause significant stress for many affected individuals, and leads to major difficulties in social settings, while shopping, at restaurants, and in institutional settings such as seniors’ residences or university cafeterias. The increased cost of food only adds to the distress, and can be particularly punishing for low-income individuals, many of whom also have to support celiac children.

Presently, the Government of Canada does provide limited financial assistance, in the form of a tax program that is extremely complex and of limited value to many Canadians. The incremental cost between a regular price and a gluten-free price may be claimed, with proper receipts and medical documentation, as a medical expense. To offer the support in this fashion is not only costly for the Government of Canada to administer and enforce, but it also adds even more to the stress of a celiac disease diagnosis. As well, the benefits (or lack thereof) of this measure are greatly impacted by one’s income and other medical expenses that can be claimed through this avenue.

In 2016, the House of Commons Standing Committee on Finance called for the simplification of the tax system in Canada,[2] and one measure to that end – to the benefit of Canadians afflicted by this terrible autoimmune disease – would be to provide a refundable tax credit to help offset the high cost of gluten-free food. Such an approach would ensure that the financial support is accessible to all, regardless of income, employment or health status, and would be much simpler to administer. As is the case with the current regime, requiring recipients to possess valid documentation proving a celiac diagnosis is reasonable, thus ensuring limited liability for the Government of Canada.

While over 350,000 Canadians have celiac disease, estimates show that approximately 85% of those are undiagnosed, often suffering debilitating health consequences as a result. Celiac disease is infamously difficult to properly diagnose and, while the Canadian Celiac Association is working hard to increase diagnosis rates, we are still a long way off. We believe that the administration cost savings versus the current regime would help to offset this expense, and the refundable tax credit approach would help to improve the quality of life of those affected by celiac disease.

With only one budget cycle remaining prior to the next federal election, we strongly believe that this change would not only be beneficial to tens of thousands of Canadians, it is also the right thing to do. The current process is cumbersome, confusing and stressful, and disproportionately punishes Canadians with less education, lower income and who are less familiar with the intricacies of the taxation system. This change is long overdue.

I thank you in advance for taking the time to read my letter, and for considering our request. The Canadian Celiac Association would be more than pleased to meet with your officials to discuss this proposal in greater detail.

We look forward to your reply.

Yours truly,

Treena Duncan

President, Canadian Celiac Association

[1] https://www.ncbi.nlm.nih.gov/pubmed/18783640

[2] https://business.financialpost.com/personal-finance/taxes/simplifying-the-tax-system-among-recommendations-to-help-cra-tackle-tax-evasion-and-avoidance