Category: Canada Revenue Agency

Canada Revenue Agency / Capital gains / Capital Gains Tax / Double Tax Treaty / Income Tax Act / Legislation / Tax Avoidance / Tax Laws / Tax Planning

Canada: “Changing Of The GAAR”: A Background On The General Anti-Avoidance Rule, And Canada’s Attempt To Expand Its Tax Power In The 2022 Budget

Published by: Mondaq - April 29, 2022

The Budget purports to introduce several new financial and taxation regimes, as well as enhance several existing mechanisms. One of the existing taxation mechanisms proposed to be amended is the General Anti-Avoidance Rule (the "GAAR"). The Government initially indicated they would be amending the GAAR in the 2021 Budget. The 2022 Budget now provides some additional detail, though we are still waiting for the actual legislation. ... - Continue reading

Canada / Canada Revenue Agency / Government Bodies / Related party Transactions / Transfer pricing

Canada: COVID-19 Just Made Transfer Pricing More Difficult

Published by: Mondaq - October 28, 2020

The COVID-19 pandemic has made the lives of hundreds of millions of people around the world uncertain, wreaking havoc on all aspects of our daily lives. Governments and taxing authorities are grappling with not only how to keep the broader macroeconomy viable over the short run, but also how to bring the economy back to fiscal balance in the medium and longer term. In an article published by the Gowling WLG Transfer Pricing & Competent Authority Group entitled "CRA Audit Activity: The Calm before the Storm?", it was hypothesized that the Canada Revenue Agency ("CRA") would likely step up audit activity, after the COVID-19 episode is finally behind us, to reign in government deficits. ... - Continue reading

Canada Revenue Agency / Capital gains / Double Taxation / Exemptions / G7 / Government Bodies / Interest / Lease / OECD / Tax Credit / Tax Planning

Canada: Don’t Let Your Dream Vacation Home Become A Tax Nightmare

Published by: Mondaq - July 29, 2020

Renting your foreign property may require you to disclose information to the Canada Revenue Agency (the "CRA"). A Foreign Income Verification Statement is required to be filed with the CRA where the adjusted cost base of the property exceeds CDN $100,000.  ... - Continue reading

Australian Taxation Office / Canada Revenue Agency / HM Revenue & Customs / Internal Revenue Service (IRS) / Tax Evasion / Tax Laws

Int’l task force sees success in cracking down on tax crimes

Published by: Accounting Today - July 13, 2020

The tax crime-fighting group including the Australian Taxation Office (ATO, the Canadian Revenue Agency (CRA), the Dutch Fiscal Information and Investigation Service (FIOD), Her Majesty’s Revenue and Customs (HMRC) from the U.K. and the Internal Revenue Service Criminal Investigation Division (IRS-CI) from the U.S sees a silver lining regarding its purpose. ... - Continue reading

Business / Canada / Canada Revenue Agency / Individuals / Law Firm / Panama / Revenue / Tax Haven / Tax Haven Investments

Canadians for Tax Fairness concerned about inaction on Panama Papers

Posted On: August 21, 2019

It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading

Canada / Canada Revenue Agency / Goods and Services Tax / Income Tax Act / Tax Evasion / Tax evasion investigations / Tax Fraud / Tax Laws / Vancouver

Metro Vancouver developer and builder sentenced for tax evasion

Posted On: May 3, 2019

A developer and builder based in Anmore has been found guilty of tax evasion and making false statements under the Income Tax Act, the Canada Revenue Agency (CRA) announced on Friday. According to the CRA, Willi Isaak was sentenced to pay a $23,100 fine, after being found guilty on two… – Continue reading

Barbados / Bermuda / Canada / Canada Revenue Agency / Caribbean / Cayman Islands / Corporate Tax / G7 / IMF / Investments / Jurisdiction / Luxembourg / Offshore Tax Haven / Tax Avoidance / Tax Collection / Tax Dodging / Tax Laws / United Kingdom / USA

Corporate Canada’s Pile of Cash in Offshore Tax Havens Has Hit $353 Billion For the First Time in History

Posted On: April 26, 2019

Luxembourg, Barbados and Bermuda are three of Canada’s top five destinations in the world for corporate cash After exploding to record levels under Stephen Harper’s Conservative government, the amount of money Corporate Canada is funneling through offshore tax havens has hit a new all-time high. According to data newly released… – Continue reading

Amazon / Beneficial Ownership / Canada / Canada Revenue Agency / Google / Netflix / OECD / Offshore / Profit Shifting / Tax Avoidance / Tax Haven / Uber

Tax Netflix and other e-commerce companies, say Canadians and CRA professionals

Posted On: February 21, 2019

OTTAWA, Feb. 21, 2019 (GLOBE NEWSWIRE) — The federal government needn’t worry about a consumer backlash to a sales tax on Canadians’ Netflix accounts, if newly released results from an Environics Research poll and a separate survey of Canada Revenue Agency (CRA) tax professionals are any indication, says the Professional… – Continue reading

Canada / Canada Revenue Agency / Citizenship / Compliant / FATCA / Financial Institutions / Internal Revenue Service (IRS) / USA

1.6 million Canadian banking records shared with IRS

Posted On: January 23, 2019

CRA now transferring 600,000 banking records per year under controversial information sharing agreement The Canadian government has shared more than 1.6 million Canadian banking records with the U.S. Internal Revenue Service since the start of a controversial information-sharing agreement in 2014, CBC News has learned. In 2016 and again in… – Continue reading

Canada / Canada Revenue Agency / Tax Avoidance / Tax Evasion / Whistleblower

Canada should invest more to prevent tax evasion, say Canadians and CRA tax professionals

Posted On: December 3, 2018

OTTAWA, Dec. 03, 2018 (GLOBE NEWSWIRE) — A large majority of Canadians (77%) agree “It would be a good investment for the Government of Canada to allocate more resources towards preventing tax evasion and avoidance,” according to a recent Environics Research poll. The poll was commissioned by the Professional Institute… – Continue reading

Canada / Canada Revenue Agency / Common Reporting Standard / Income Tax Act / Jurisdiction / OECD / Offshore / Offshore Banking / Offshore Fund / Residence / Tax Authority / Tax Transparency

Canada: Common Reporting Standard Is Now Fully In Effect – If You Have Been Hiding Funds Or Assets Offshore, Now Is The Time To Disclose

Posted On: November 28, 2018

Introduction – Offshore funds and Canada Revenue Agency’ reach Gone are the days when offshore bank accounts were outside the Canada Revenue Agency (CRA)’s reach. With the advent of the Common Reporting Standard (CRS), CRA automatically receives financial information of Canadian taxpayers who own bank accounts or assets in other… – Continue reading

Canada / Canada Revenue Agency / Jurisdiction / Residence / Residency / Residential Property

Canada: Tax Residence In Canada – Are Significant Residential Ties Less Significant For Immigrants To Canada Than For Emigrants From Canada? A Canadian Tax Lawyer’s Analysis

Posted On: November 2, 2018

Introduction A person’s status as a tax resident determines the extent to which Canada may tax that person’s income. The test for whether an individual—i.e., a natural person—is a Canadian tax resident turns on the individual’s particular circumstances. Every detail counts. But Canadian courts and the Canada Revenue Agency both… – Continue reading

British Virgin Islands / Canada / Canada Revenue Agency / Cayman Islands / FATF / Offshore Trusts / Tax Collection / Tax Haven / Tax Laws / Trust

Ottawa Implementing New Reporting Rules For Trust Funds

Posted On: June 25, 2018

The federal government has introduced sweeping new reporting rules for private trust funds, which have been accused of hiding wealthy Canadians’ money from tax collectors. Going forward, trusts that fail to file a tax return will face fines equalling 5% of its total value. The Canadian government still has no… – Continue reading

Canada / Canada Revenue Agency / Income Tax / Interest / Tax Authority / Voluntary Disclosure Program

CRA finalizes new Information Circular for income tax Voluntary Disclosures Program

Posted On: December 18, 2017

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… – Continue reading

Canada / Canada Revenue Agency / Capital gains / Individuals / Jurisdiction / Property / Residence / Tax Dispute / Tax treaties

Ten important Canadian Tax compliance considerations for new Canadians

Posted On: December 1, 2017

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… – Continue reading

Banking / Canada / Canada Revenue Agency / Israel / Tax Authority / Tax Evasion / Tax evasion investigations / USA / Voluntary Disclosure Program

Hapoalim Canadian customers say bank aided tax evasion

Posted On: November 15, 2017

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…. – Continue reading

Canada / Canada Revenue Agency / Legislation / Privacy / Real Estate / Residence / Tax Fraud / Vancouver / Withholding Tax

Court orders developer to reveal condo-flipper info

Posted On: October 10, 2017

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… – Continue reading

Canada / Canada Revenue Agency / Gaar / Tax Avoidance / Tax Evasion / Tax treaties

CRA Provides Update On Tax Avoidance Crackdown

Posted On: September 12, 2017

Canada’s Revenue Minister has provided an update on the progress made by the Government in addressing tax evasion and aggressive tax avoidance. The update concerns the recommendations on tackling tax avoidance and evasion made by the House of Commons Standing Committee on Finance (FINA) in October 2016, and the actions… – Continue reading

Canada / Canada Revenue Agency / Common Reporting Standard / Offshore Tax Haven / Privacy / Residence / Tax cheats / Tax Evasion

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

Posted On: July 18, 2017

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… – Continue reading

Americans / Banking / Canada / Canada Revenue Agency / Citizenship / FATCA / IGA / IRS / Legislation / Offshore Tax Evasion / Offshore Tax Haven / Rand Paul / Tax cheats / Tax Evasion / USA

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

Posted On: April 27, 2017

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… – Continue reading

Canada / Canada Revenue Agency / Individuals / Multinational Corporations / Offshore / Revenue / Tax Break / Tax cheats / Tax Evasion / Tax Haven

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

Posted On: March 22, 2017

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…. – Continue reading

Canada / Canada Revenue Agency / High Networth Individuals / Isle of Man / KPMG / Offshore / Offshore Companies / Regulatory / Tax Avoidance / Tax Dodging / Tax Evasion / Tax evasion investigations

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

Posted On: March 2, 2017

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… – Continue reading

Accounts and Audit / Canada / Canada Revenue Agency / Guernsey / Isle of Man / Offshore Tax Informant Program / Panama / Tax Avoidance / Tax cheats / Tax Evasion / Tax evasion investigations / Voluntary Disclosure Program

Canada To Ramp Up Efforts Against Tax Evasion

Posted On: February 27, 2017

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… – Continue reading

Canada / Canada Revenue Agency / Legislation / Offshore Tax Evasion / Offshore Tax Haven / Tax cheats / Tax Evasion / Tax Laws / USA

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

Posted On: February 21, 2017

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… – Continue reading

Canada / Canada Revenue Agency / Legislation / Property / Tax Laws / Transfer pricing

CRA says there is no limitation period for the 10% transfer pricing penalty

Posted On: February 21, 2017

The CRA has the power to make a transfer pricing adjustment to any amount for a taxation year under s. 247(2) in respect of a non-arm’s length cross-border transaction. A taxpayer is also liable to a 10% penalty under s. 247(3), which penalty is determined with reference to the taxpayer’s… – Continue reading

Americans / Banking / Canada / Canada Revenue Agency / FATCA / IRS / Legislation / Privacy / Residency / Tax Evasion / USA

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

Posted On: January 29, 2017

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… – Continue reading

Canada / Canada Revenue Agency / Offshore / Offshore Accounts / Panama / Tax cheats / Tax Evasion / Voluntary Disclosure Program

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

Posted On: December 8, 2016

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… – Continue reading

Brussels / Business / Canada / Canada Revenue Agency / Corruption / Directors / Europe / Individuals / Law Firm / Offshore / Offshore Tax Haven / Panama / Revenue / Tax Avoidance / Tax cheats / Tax Evasion / Tax Haven / Trust / Trustee

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

Posted On: November 15, 2016

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… – Continue reading

Activity / Automatic Exchange of Information / Britain / Canada / Canada Revenue Agency / David Cameron / Jurisdiction / Law Firm / OECD / Offshore Companies / Offshore Tax Evasion / Offshore Tax Haven / Panama / Property / Regulatory / Revenue / Tax cheats / Tax Evasion / Trust / United Kingdom

CRA investigating 85 Canadians for tax evasion tied to Panama Papers

Posted On: November 14, 2016

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… – Continue reading

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