Greg DelBigio, Q.C. has advised and acted on behalf of individual taxpayers, corporations and tax advisors during audits, criminal investigations and after criminal charges have been approved. Read complete profile »
In February, the United States Department of Justice entered into a deferred prosecution agreement with Swiss bank, Rahn and Bodmer (R+B). The agreement refers to the criminal charge that R+B conspired with others to defraud the IRS, to file false…
We last wrote about the Land Owner Transparency Act (“LOTA”) on May 23, 2019. On November 30, 2020, the BC Ministry of Finance announced that the LOTA registry has now launched.
In the announcement, the Ministry was unambiguous…
A recent American Bar Association Practice Point article posed the question: may tax evasion be charged as a money laundering offence? In Canada, the answer is unequivocally, yes – the acts that result in a charge of tax evasion…
The BC government’s recent focus on tax evasion and money laundering in the real estate market has led to proposed legislation, the Land Owner Transparency Act (Bill 23 – 2019), which will impose potentially onerous disclosure requirements on those who…
In Budget 2019, the federal government continues to bolster its tools and resources to detect and prosecute tax evasion and money laundering. These proposals are relevant both to those who do not pay the amount of tax the law requires,…
The Australian Taxation Office (ATO) recently announced that, through a consultation process, it is examining the use and, more particularly, what it says are occasions of misuse of claims of solicitor-client privilege. The Consultation is interesting but, it also provides…
Under the provisions of the Income Tax Act (the “ITA”), the CRA is authorized to inspect a taxpayer’s books and records and to require taxpayers to provide information and documents in the course of an income tax audit. However, the…
I last wrote about the decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61 on April 10, 2017. In that decision the Court imposed important restrictions upon the use of the s.231.1(1) audit powers by…
The Income Tax Act provides CRA with broad powers of administration and enforcement. In BP Energy Company v. Minister of National Revenue, 2017 FCA 61, the appeal court considered the authority to conduct the inspection of books and records given…
If a year is to end with something that causes a bang, then the decision in Minister of National Revenue v. Iggillis Holdings Inc. and Ian Gillis Et Al., 2016 FC 1352 did just that. In reasons that are ambitious,…