Principal Issues: Information regarding the paragraph 95(6)(b) committee.
Position: Please see attached document.
IFA Roundtable, May 2014 Question 6
Question 6: Paragraph 95(6)(b)
Who are the members of the 95(6)(b) Committee? How often does the Committee meet? Please provide statistics for referrals to the Committee 2010 forward, if possible, broken down by year. How many cases are before the courts?
CRA Response
The Committee is chaired by Mark Turnbull, the Manager of the International Advisory Services Section of the International Tax Division of the International & Large Business Directorate at Compliance Programs Branch. Other members include Len Lubbers, Jim Randall, Suzanne Saydeh and Paul Stesco also from the International & Large Business Directorate of the Compliance Programs Branch and Olli Laurikainen from the Income Tax Rulings Directorate of the Legislative Policy and Regulatory Affairs Branch.
The number of meetings per year is not pre-determined but rather is on an as needed basis, and varies according to the number of referrals received over any given time.
The Committee has not kept statistics on a year-by-year basis. However, over the four year period 2010-2013 a total of 19 cases were considered by the Committee. In seven of those cases it was recommended that paragraph 95(6)(b) be applied.
At this time there are two paragraph 95(6)(b) cases before the courts.
Olli Laurikainen
2014-052676