Policy Forum: Tax Filing as State Administrative Infrastructure--Governance Gaps in Canada's Tax-Based Benefit System

Canada's tax system has become the primary administrative gateway to income-tested programs across all orders of government, yet its governance remains oriented toward revenue collection and tax base harmonization rather than access and coordination. Each year, a significant share of Canadians--disproportionately those with low incomes--do not file a tax return, despite being most likely to qualify for tax-based and tax-verified programs. As reliance on tax filing and income data held by the Canada Revenue Agency has expanded, access failures reflect not individual behaviour but gaps in administrative stewardship. We argue that tax administration now operates as shared state administrative infrastructure: a durable system of legal authorities, data practices, and administrative processes on which multiple governments rely to deliver social policy. Existing intergovernmental arrangements were not designed to manage this shared dependency. We document how fragmented governance impedes outreach, error resolution, and benefit takeup, even as Canada moves toward simplified and automatic tax filing. We propose a tax-filing and benefit access accord: a light-touch intergovernmental framework built on shared stewardship of filing supports, consent-based data coordination, and integrated service design. The accord does not centralize benefit delivery or expand entitlements; it aligns governance with the administrative realities of tax-based benefit delivery in a decentralized federation.