Category: Canada

Barbados Agrees To Phase Out Harmful Tax Regimes

Two Barbados preferential tax regimes have been labelled “potentially harmful” in additional guidance released by the OECD in connection with its base erosion and profit shifting (BEPS) project. The guidance singles out Barbados’s international financial services regime and its credit for foreign currency earnings/credit for overseas projects or services regime....

Offshore Pensions in Millions

Offshore tax havens conjure up a wonderland for the well-heeled and their wealth. But investigations based on the Paradise Papers leak has found that millions of ordinary Canadians also have an interest in money parked in tax havens — almost certainly without knowing it. Seven of the country’s so-called Big...

CRA finalizes new Information Circular for income tax Voluntary Disclosures Program

On December 15, 2017, the CRA released the final version of Information Circular IC 00-1R6 – Voluntary Disclosures Program (“VDP”) for income tax, after receiving and considering community input on the June 2017 draft version. This article summarizes the important differences between the draft and the final ICs and discusses...

Ten important Canadian Tax compliance considerations for new Canadians

The Canada Revenue Agency’s recently announced “postal code project” targets Canada’s richest neighbourhoods, to identify non-compliance apparent from discrepancies between residents’ tax reporting with their apparent wealth. Even prior to the postal code project, which focuses on any potential high net worth individual, the CRA had enhanced audit activity on...

New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?

In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the...

Jahangir Tareen’s ‘Trust Deed’ signed and executed in Switzerland

ISLAMABAD/LONDON: The thirty-eight-page trust deed of Pakistan Tehreek-e-Insaaf (PTI) leader Jahangir Khan Tareen’s offshore trust was signed and formalised in Geneva, Switzerland, and facilitated by HSBC Guyerzeller Trust Company Geneva – raising questions about Swiss bank accounts. During the hearing before Pakistan’s Supreme Court, Tareen was asked no questions about...

Hapoalim Canadian customers say bank aided tax evasion

114 taxpayers in Canada’s voluntary disclosure program say that the Israeli bank helped them evade taxes. As if the headache of the investigation by US authorities were not enough, Bank Hapoalim (TASE: POLI), managed by CEO Arik Pinto, discovered two days ago that Canada was also taking aim at it....

Paradise Papers: ICIJ releases another database revealing offshore companies

The International Consortium of Investigative Journalists (ICIJ) has released a database of around 13.4 million documents revealing over 25,000 companies owned by the world’s rich and influential individuals. The ICIJ coordinated the Panama Papers investigation into offshore companies. The latest files have disclosed the financial details of politicians, corporations, and...

Court orders developer to reveal condo-flipper info

A Federal Court judge has approved at least one court order that will require a British Columbia developer to turn over information to tax officials about people who bought and flipped condo units before or during construction. And several similar applications are under way, reflecting the federal government’s efforts to...

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...