Thanks for making the submission and copying me. Having read your e-mail I have a concern about the exclusive use of the term ETF.
I realize that most Canadians are affected only through ownership of ETFs, however this legislation also affects open-ended mutual funds (e.g. Vanguard, Fidelity, Janus, et al), closed-ended mutual funds (like ETFs but minus the creation unit mechanism to arbitrage out the premium/discount to NAV), and -- if Jon's last FP column is correct -- even the shares of certain companies like MSFT and BRK. (There are many reasons why Canadians might own US-based mutual funds even though they are not generally available in Canada as are ETFs and stocks. The campaign website gives several such reasons.)
I'm concerned that because many people who make submissions to Ottawa own only ETFs they understandably request only that the exemption from the new legislation be reinstated for ETFs, i.e. without mentioning any of the other types of securities. It would be a real pity if we got exactly (and only) what you're asking for, because that would leave everyone else in the predicament that we all face today. That's why I refer to "US-based mutual funds and ETFs" on the website. Even that terminology may be too narrow if it turns out that certain stocks are also affected.
Perhaps a better term is something like publicly-traded US investment funds and stocks.
Any CAs or tax lawyers out there who can clarify this point?