Category: Canada

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the...

Canadian Businesses Urge Gov’t To Scrap Tax Plans

Thirty-five Canadian business organizations have written to Finance Minister Bill Morneau to ask that he scrap proposals to crack down on the use of tax planning strategies by private corporations. The business groups have together formed the Coalition for Small Business Tax Fairness to oppose the Government’s proposals. Signatories of...

Court Rules In Favor Of Taxpayer In Canadian TP Audit Case

The Federal Court of Canada has ruled that the Canadian Revenue Agency may not conduct further in-person interviews with representatives from a multinational corporation concerning its transfer pricing affairs, having already discussed earlier tax years. Cameco Corporation declined to produce approximately 25 personnel for oral interviews in relation to an...

‘Come to CRA before we go to you’: International deal designed to expose offshore tax cheats

Canada and dozens of other countries will automatically share banking information of non-residents Canadians with secret overseas bank accounts could soon find themselves at risk of being exposed by a new international agreement designed to help catch tax cheats. Under the Common Reporting Standard, dozens of countries will share information...

Morneau ‘laying down the gauntlet’ on corporate tax loopholes

The finance minister says federal government doesn’t “want to wait for the next Panama Papers.” Canada’s finance minister denounced “unfair” tax loopholes on Thursday and put Bay St. on notice that the Liberal government is committed to addressing “blind spots” and exposing shadowy corporate finances to public scrutiny. “We don’t...

Deal that sends Canadian bank records to IRS is ‘illegal,’ lawyer tells U.S. committee

Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on...

G20 Citizens Favor BEPS Crackdown Over Tax Competition

Citizens in G20 countries would prefer their government engage in international efforts to improve the functioning of international tax rules than compete for tax receipts, says a new survey. G20 public trust in tax, a report compiled by the ACCA (the Association of Chartered Certified Accountants), IFAC (the International Federation...

Tax haven label haunts Barbados

There is a worrying perception of Barbados on as a tax haven, a view that is hampering the island’s status as a jurisdiction in which to do business, says President of the Barbados International Business Association (BIBA) Gregory McConnie. Equally troubling, McConnie says, is that Barbados’ primary investing jurisdiction, Canada,...

Ottawa to spend $500M on pursuit of tax cheats, budget reveals

Money will be used to hire more auditors and develop computer systems to “target high-risk international tax” evasion. Tax auditors and fraud investigators have been given more than half a billion dollars to pursue tax cheats, and the government expects them to collect five times that much in additional taxes....

KPMG offshore tax dodge a ‘facade’ designed to hide money, ex-client says

Accounting firm’s contracts with federal government questioned. A former client of the accounting giant KPMG says a tax dodge that involved wealthy people gifting their money to an offshore jurisdiction was a “facade” designed to hide money from the taxman. The client, who spoke to CBC’s the fifth estate and...

Canada To Ramp Up Efforts Against Tax Evasion

The Canadian Government has said that it will review its tax ruling process and voluntary disclosures program as part of its response to recommendations made last year by a parliamentary committee. In October 2016, the Standing Committee on Finance released its report on the Canada Revenue Agency’s (CRA’s) efforts to...

CRA’s new fingerprinting policy could create travel problems for accused tax evaders

Tax agency calls mandatory fingerprinting ‘a powerful deterrent’ The Canada Revenue Agency’s new policy to fingerprint every person it charges with tax evasion could create travel problems at the U.S. border for some Canadians who haven’t had their day in court The Canada Revenue Agency has begun to record the...

Transfer of Canadian banking records to U.S. tax agency doubled last year

Documents for thousands of Canadian residents transferred under controversial FATCA legislation Banking records of more than 315,000 Canadian residents were turned over to the U.S. Internal Revenue Service last year under a controversial information sharing deal, CBC News has learned. That is double the number transferred in the deal’s first...

‘Tax haven’ Canada being used by offshore cheats, Panama Papers show

Country’s reputation being exploited for ‘snow washing’ global money trails, experts warn Far from the palm-fringed beaches of the usual offshore tax havens, Canada has quietly become a go-to destination for international tax cheats eager to exploit the country’s twin benefits of a sterling reputation and rules that allow private...

Canada: Report On The Voluntary Disclosures Program (VDP) – Canadian Tax Consultant Analysis

The Offshore Compliance Advisory Committee issued a report in December 2016 to the Canada Revenue Agency about the Voluntary Disclosures Program (VDP or tax amnesty). If a taxpayer submits a successful income tax or GST/HST voluntary disclosure program application then generally criminal income tax prosecution and civil tax penalties under...

From Israel to Canada: New Tax Treaty to Help Structure Investments

On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,...

Canada Revenue Agency monitoring Facebook, Twitter posts of some Canadians

Agency is increasingly turning to cutting-edge data analysis techniques to improve service and ‘compliance’ The Canada Revenue Agency is scrutinizing the Facebook pages, Twitter feeds and other social media posts of Canadians it suspects could be cheating on their taxes. That’s just one example of the agency’s increasing focus on...

U.S. tax reform plan “not likely” to badly impact Canada: Expert

WASHINGTON — An American tax authority who helped champion a reform now being considered by the U.S. Congress says Canada would not be among the countries hardest hit by the introduction of so-called border adjustments. Alan Auerbach is among the leading proponents of the push to restructure corporate taxes so...

Snapchat opts for London over Dublin for international HQ

Move could be a worrying indicator of investment trends post-Brexit, post-Beps Snap, the company behind Snapchat, has opted to open its new new international headquarters in London, rather than Dublin, Amsterdam or Luxembourg, bucking a trend which for decades has seen US multinationals book their international sales in one of...

A Classic Case Of Double Taxation?

The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular...

CRA must toughen up voluntary disclosure for tax cheats, panel says

The Canada Revenue Agency needs to toughen up the program that offers advantageous deals to tax cheats, especially in cases where large amounts of income were not declared through deliberate schemes, a federally appointed committee says. In a report released Thursday, the Offshore Compliance Advisory Committee called for a series...

Switzerland eyes AEOI with 21 countries

Switzerland, which has been working to end its years-long practice of banking secrecy, on Thursday said it aimed to dramatically increase the number of countries it cooperates with toward international fiscal transparency. The Swiss government said in a statement that it wanted to extend the automatic exchange of information (AEOI)...

Switzerland Adopts Ordinance On International AEOI

Switzerland’s Ordinance on the International Automatic Exchange of Information (AEOI) in Tax Matters will enter into force on January 1, 2017. The Swiss Federal Council adopted the ordinance on November 23. The ordinance contains the Federal Council’s implementing provisions for the Federal Act on the International Automatic Exchange of Information...

Anti-terrorism tactics should be applied to tax havens, report says

The same aggressive and uncompromising international effort used to combat terrorism must be employed to eliminate tax havens, says Nobel Prize-winning economist Joseph Stiglitz in a report being released Tuesday. In a copy of the report, obtained by the International Consortium of Investigative Journalists and shared with the Star, Stiglitz...

CRA investigating 85 Canadians for tax evasion tied to Panama Papers

Eighty-five Canadians identified in the Panama Papers leak are now being investigated for tax evasion, the Canada Revenue Agency has revealed. Details of Canada’s enforcement effort were provided to the Star the same week the U.K., which is a major hub of the offshore finance world, said it has launched...

Significant Change In CRA Policy Harms Canadian Investors In US LLPs And LLLPs

Earlier this year the Canada Revenue Agency (“CRA”) announced its new administrative position that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) formed under the laws of Delaware and Florida are properly viewed as corporations for Canadian income tax purposes. It is widely expected that LLPs and LLLPs...

Trump’s Corporate Tax Reforms: What CFOs Need to Know

While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital...

Nearly 100 Countries Poised to Adopt Multilateral Treaty

Ninety-eight countries are poised to formally adopt the OECD’s innovative multilateral tax treaty, which will place recommendations from the BEPS project into more than 3,000 bilateral accords, when the ad-hoc group meets later this month. The “Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting”...

OECD Reviewing U.S. Handling of Double-Tax Cases

The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a...

Armenia eliminates double taxation of property and income with Serbia and Slovakia

The Armenian Parliament has ratified today two agreements to avoid double taxation and prevent tax evasion with respect to taxes on property and income with Serbia and Slovakia. According to Deputy Minister of Finance Armen Hayrapetyan, the document on the mutual avoidance of double taxation on property and income with...

CANADA, ISRAEL SIGN AGREEMENT ON DOUBLE TAXATION

CANADA, ISRAEL SIGN AGREEMENT ON DOUBLE TAXATION As Prime Minister Justin Trudeau joined other world leaders in addressing the United Nations General Assembly, behind the glare of the camera lights, Foreign Affairs Minister Stéphane Dion met with Israel’s Finance Minster Moshe Kahlon on the sidelines to sign an agreement to...

Canadians in Panama Papers shouldn’t expect a tax deal, CRA says

More than 2,000 files under review, 85 taxpayers under audit National Revenue Minister Diane Lebouthillier said in a statement Monday that a few thousand files are now being pursued by the tax agency after it sifted through the Panama Papers. Canadians implicated in the Panama Papers shouldn’t expect any leniency...

Bahamas files: New leak exposes offshore ‘tax haven’ dealings of politicians, companies

Five months after the Panama Papers exposed the offshore dealings of government leaders and influential people, a new leak of 1.3 million files has revealed the names of individuals associated with companies registered in the Bahamas, a notorious tax haven. The files – received by the German newspaper Süddeutsche Zeitung...

New Zealand extends anti-money laundering rules to capture property agents

New Zealand will extend its anti-money laundering laws to cover real estate agents and other professions amid fears the country has become a soft target for illegal fund flows that have also helped inflate the property market. Soaring property prices have become a hot issue among the New Zealand public...

EU Commission names countries that may need tax avoidance screening

The European Commission published on Thursday a list of 81 countries and jurisdictions that have a higher chance of facilitating tax avoidance and may be subject to further screening and even sanctions if all EU states agree. The “scoreboard” is the first step in a process that should be concluded...