Mr. Speaker, with respect to the above-noted question, what follows is the response from the CRA.
In response to part (a), as of December 25, 2020, the most recent data available, the CRA defines “files” as audits, and there are 160 taxpayers audits currently ongoing related to the Panama papers and close to 50 audits currently ongoing related to the paradise papers.
In response to part (b), as of March 31, 2020, the most recent data available, no cases related to the Panama papers or the paradise papers have been referred to the Public Prosecution Service of Canada, PPSC.
Criminal investigations can be complex and require years to complete. The length of time required to investigate is dependent on the complexity of the case, the number and sophistication of individuals involved, the availability of information or evidence, the co-operation or lack thereof of witnesses or the accused, and the various legal tools that may need to be employed to gather sufficient evidence to establish a case beyond reasonable doubt.
In response to part (c), the CRA is interpreting the term “employees” as noted in the question as the budgeted full-time equivalents, FTEs, in the auditors, AU, category: 37 auditors are assigned to the Panama papers workloads, and 14 auditors are assigned to the paradise papers workloads. It is important to note that these auditors are not solely dedicated to Panama papers and paradise papers, and some auditors work on both the Panama papers and the paradise papers workloads.
In response to part (d), as of December 25, 2020, the most recent data available, the CRA has completed close to 200 taxpayer audits linked to the Panama papers and close to 80 taxpayer audits linked to the paradise papers.
In response to part (e), as of December 25, 2020, the most recent data available, there have been over 35 audits resulting in reassessment for the Panama papers and under five for the paradise papers that resulted in tax earned by audit, TEBA.
It is important to note that with each individual audit, there may be multiple notices of reassessment issued to each taxpayer depending on the number of years audited and whether penalties are applicable to the audit. For example, if there are six years under audit, there can be potential for several notices of reassessment issued for the one taxpayer audit should non-compliance be identified.
In response to part (f), the CRA is unable to respond in the manner requested, as it does not track payments against specific account adjustments like audits, as its systems apply payments to a taxpayer’s cumulative outstanding balance by tax year, which can represent multiple assessments, reassessments such as audits of different types, and other adjustments.
However, based on an October 2020 study by the Parliamentary Budget Officer of recent federal budget investments in the CRA tax compliance operations, it was generally estimated that approximately 80% of total audit fiscal impact will materialize and result in successful collection actions.
In response to part (g), the CRA is defining “case” as an audit. Please note that there are many factors that could impact the amount of time to complete a Panama papers and paradise papers audit, such as the time from the date the case is created to the date the case is assigned to an auditor; delays beyond our control such as the time it takes the taxpayer to respond to questions; cases involving offshore assets require exchange of information with other jurisdictions, other tax administrations, which can take a significant time. The average time to complete a Panama papers audit is close to 380 days per audit and close to 360 days per audit for paradise papers.
In response to part (h), as outlined in part (d), there have been close to 280 taxpayers audits completed linked to the Panama papers and paradise papers, resulting in more than $21 million in federal taxes and penalties assessed. The average return, TEBA, for closed audits for the Panama papers is $110,216.
However, as noted under part (e), to date, there have been fewer than five taxpayer audits with links to the paradise papers that resulted in non-compliance. Under the confidentiality provisions of the acts administered by the CRA, in situations where the sample size is so small that a taxpayer or business could be directly or indirectly identified, aggregate data is not released. Therefore, disclosing dollar values related to paradise papers cannot be provided as the identities of the taxpayers or businesses could be revealed or inferred.
In response to part (i), under the confidentiality provisions of the acts administered by the CRA, in situations where the sample size is so small that a recipient could be directly or indirectly identified, aggregate data is not released. Given the small volume of cases and the need to ensure confidentiality, the details cannot be provided as the identities of the taxpayers or businesses could be revealed or inferred.