This BBC story on fighting tax avoidance by multinationals is rather short on substance. No doubt the Devil will be in the details.
Some tax issues for criminal lawyers
This article originally appeared in the Hamilton Law Association Journal.
A client facing criminal charges would seem to have enough on his or her plate—like the possibility of serving a jail sentence—without having to worry about tax issues. The CRA, however, will be only too happy to pile on where it thinks the accused has earned income that should be subject to tax.
Tax schemes
Two recent cases address unsuccessful attempts to avoid tax by dubious means.
Why the hiatus?
I haven’t posted to this blog since late June, which is probably the longest break I’ve taken from writing posts. The reason for not posting is a good one, however: effective August 1, I began practising law on my own…
New T1135
In the headlines today: the “Harper Government announces new requirements for Canadians with offshore property and income”. Accountants have been waiting for this announcement in fear and trembling. The added work at tax time will not be insignificant.
Paying whistleblowers
The CRA has traditionally not offered rewards to whistleblowers, and so it is not surprising that they “missed out” recently on a chance to obtain information on possible tax cheats. Of course, the policy has now changed. It’d be interesting…
Legal project management
Legal project management (LPM) is all the rage in certain quarters. It’s not a new idea, of course. I remember talking about it with some of the lawyers in the large firm I worked for in Toronto in the mid-90s. There wasn’t much appetite for LPM software at the time, I think in part because some of the tools available then appeared too inflexible for the typical M&A deal.
Pendulum swing
Redeemer Foundation v Canada (National Revenue), 2008 SCC 46, makes it clear that the CRA has broad powers to demand information relating to unnamed third parties, sometimes even without the need for prior judicial authorization (as per subsection 231.2(2)). Two…
Rectification denied
From the “There But for the Grace of God Go I” file, see Kanji v AG Canada, 2013 ONSC 781. It’s striking that the trial judge was so troubled by the lack of supporting evidence from Mr Kanji’s professional advisers…
The Search for Revenue
The trend continues. The CBC made a big deal (and rightly so) out of a disclosure of a huge amount of data on offshore bank accounts made to the director of the International Consortium of Investigative Journalists. It appears that German tax authorities have purchased a CD containing information on deposits made to Swiss bank accounts. The authorities purchased the data for €4 million but they expect to recover €500 million in taxes using the data. That’s a pretty good return on their investment (even taking into account the collections costs).