Canada taxes its residents on their worldwide income, including income earned and gains realized outside Canada (subject to the potential application of specific rules in tax treaties). The federal Income Tax Act (the “ITA”) also requires that residents disclose specific…
Authored by: Greg DelBigio, Q.C. and Morgan Watchorn
In Budget 2021, the federal government proposes to provide the Canada Revenue Agency (the “CRA”) with $230 million over five years as part of an ongoing focus on enforcing civil liabilities…
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…
The SCC decision in Canada (Minister of Citizenship and Immigration) v Vavilov (2019 SCC 65) (“Vavilov”) and its companion case Bell Canada v. Canada (Attorney General) (2019 SCC 66) established a new framework that Courts must follow when reviewing decisions…
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,…