Principal Issues: Update on CRA's International Tax Planning Centres of Expertise.
Position: See document.
CLHIA ROUNDTABLE - MAY 2007
Question 9
CRA's International Tax Planning Centres of Expertise
Could you provide an update regarding the CRA's Initiative to setup 11 International Tax Planning Centres of Expertise, as well as information on the focus of these centres?
Agency's Response
The 2005 federal budget allocated $30 million to address aggressive international tax planning (AITP) issues. Part of this funding is being used to operate 11 Centres of Expertise (CE's), which have been set up across the country. The CE's are focused on enhancing CRA's ability to identify AITP schemes.
The workload of the CE's includes analytical research, understanding the profile of participants and promoters of certain tax schemes, establishing effective ways to target them, validating the existence of a problem using restricted audits, integrating information into CRA risk assessment models and identifying the necessary legislative amendments with a view to countering AITP schemes. The CE's are making progress on all fronts including the dissemination of information to the tax services offices.
There are about 50 projects underway, with significant tax consequences. Among other things, research is being conducted on residency issues, tax shelters, financial arrangements, hybrids, employment compensation and tax treaty abuses.