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Henry Lotin's avatar

Part 2 (Was not aware of word limit for Comments until sent)

Considerations:

1. Your comments on refugees apply to all expired visa holders.

2. Different components of Statistics Canada as well as Immigration Canada, have information on "actual status", in IRCCs case even addresses of expired visa holders with outstanding visa applications living in Canada. Statistics Canada research on visa student earnings through tax records reveals a much higher share of participation in the student visa holders in the work force. Evidence that a material number of expired student visa holders receive T slips for their pay, have deductions remitted to CRA, and are eligible to file a T1 Income Tax claim and receive a refund.

3. Up to July 1, 2021 official population estimates assumed all expired visa holders left the country within 30 days of the expiry of their visa. Upwards of 1 million temporary visas (plus) expired between the closer of international borders (across the globe) in the Spring of 2020 though to July 1, 2021. During much of 2020, departing Canada was next of impossible. Entering the country of origin of many visa holders was prohibited or restricted well after Canada's borders opened. IRCC made accommodation through blanked extensions. These were not reflected in Statistics Canada demographic data.

Statistics Canada made no adjustments to their methodology during this period. Only for population recorded after July 1, 2021 was the assumed departure period adjusted to (up to)120 days after expiry. However, the expired visa holders who remained through COVID, were removed from the data 30 days after visa expiry. Upwards of one year later (or more) after the IRCC blanket extensions (circulated through IRCC website), some returned to the count upon receipt of standard issue extensions or new temporary visas.

Many (likely hundreds of thousands) let their visas expire while awaiting permanent residency (some received years later, some others permanent residency never came), while continuing to work. Many receiving accolades as "essential workers" during COVID.

The distortions in Demographic data during COVID restrictions are profound with long-lasting implications for demographic counts and projections today. In sum, the official population undercount grew exponentially as a result.

IRCC and Statistics Canada did not collaborate on clarifying "actual status", and Statistics Canada chose not to backdate its adjustments (made in 2023) to extend the expiry cut off from 30 to 120 days after expiry, prior to July 1, 2021.

With the passage of time, and access to IRCC, CRA, and CBSA data, a restating of that population during the COVID period is possible.

In determining who should be included in the official population, your references to the International System of National Accounts (SNA) language are key to what changes are needed.

The SNA definition of a resident is one who engages... in economic activity". Receiving a T slip from ones employer along with having deductions from employment (therefore eligible for inclusion in SEPH data) is proof of engagement. Further, as you cite in your paper;

SNA definition also requires that a resident “maintains a centre of predominant economic interest in [Canada], that is, [he or she] engages, or intends to engage, in economic activities or transactions on a significant scale either indefinitely or over a long period of time, usually interpreted as one year.”

This definition would also support the inclusion of expired visa holders that register with a settlement agency for accommodation, or signs a lease with a private landlord.

I fully agree that "NPR status for an individual should not depend on his or her intent", but signing a lease is an indicator of economic activity of significant scale and economic activity over a long period of time.

I suggest your observation that "Statistics Canada has little or no information at present about their actual status until the census is conducted" needs a revisit. Statistics Canada has access to IRCC, and CBSA data now. They cannot complete their Demographic population series without accessing IRCC data. Statistics Canada researchers are examining visa student incomes using CRA Income tax data. Is Demography Division prohibited the same access?

I am sure Statistics Canada Demography will raise both cost and complexity as barriers to adjusting the definition. However, technology and new information sharing with the CBSA, and perhaps even within Statistics Canada, are key to getting, applying, and sharing better data.

Users require a better and more transparent presentation in order to plan, plan housing, infrastructure, and services. As for international comparability, data requirements change and other nations are recognize need to change as well. Recent changes in U.S. Census data releases, which I will link in separate comments, point to adjustments in U.S. counts, which have historically undercounted asylum seekers compared to the Canadian practice.

I look forward to your thoughts?

Thanks for those patient enough to read though the complete message.

Henry

Henry Lotin

Principal

Integrative Trade and Economics

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Anne Meggs's avatar

I should add that another way of working without legal status and paying taxes is with a false NAS. This, it seems, is fairly common for undocumented immigrants in the US. I have no recent information on false NAS in Canada. The Auditor General has been on the government’s case on this matter since 1998.

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