Finance committee  Thank you, Chairman. My name is Brian Ernewein. I'm the general director in the tax policy branch of the Department of Finance, and I'm joined by a few of my colleagues from the department, who may join us at the table if a question should arise. I appreciate the invitation to

Finance committee  I think this probably is a question that falls more to my colleagues at the Canada Revenue Agency in terms of tax collection, so I'll ask Mr. McAuley to respond.

Finance committee  I think the answer is that there isn't a calculation of an international tax gap done by Canada, either by Finance or by the Canada Revenue Agency or elsewhere.

Finance committee  To our knowledge, no country actually does a calculation of the international tax gap. There are some that have attempted a measurement using a lot of assumptions of a domestic tax gap, which is sometimes thought of as the underground economy, but not on the international tax fro

Finance committee  If I may, I would just correct a misperception that appears to have arisen when the previous honourable member raised a question. I think he was attributing the comment to my colleague, Mr. McAuley, but it was actually I who said that there wasn't any international calculation of

Finance committee  I will start, and then Mr. McAuley may have more to add. I will just make the point that with the tax information exchange agreements and with the revisions to our tax treaties—to make sure that all countries with which we have a relationship, and we are hoping to get a relatio

Finance committee  Let me talk specifically about what Canada is doing in that context. I've lost track of when it was done, but sometime in the last decade or 15 years, there were rules, so-called third-party penalties, introduced for tax advisors—civil penalties. There have been for many years po

Finance committee  No, excuse me, it's the contrary. Both of these regimes are really in the civil context. The third-party penalty rule was, as I said, to fill a gap instead of having only the option to proceed criminally against the tax advisor. So it created the opportunity to actually proceed o

Finance committee  This regime that is currently before Parliament has some elements of that. It also shares some features with some Quebec legislation that's in place, and it does look at these hallmarks...sorry, I'm drawing a blank in terms of the three hallmarks it has. But if you had two out of

Finance committee  I think there's a conflation of evasion and avoidance in the discussion we've been having. With respect to avoidance, yes, absolutely. The clearer the rules can be to tell people where they can go and where they're going too far, I think that's all to the greater good. In relatio

Finance committee  I'm not certain of the question, but let me answer both interpretations I may have. One is whether or not we ought to have these tax information exchange agreements with so-called tax havens. To us, the unambiguous answer is yes. They're the countries that in the past have been o

Finance committee  I was going to say zero, but that's not quite right. There was I think an exchange of information agreement with Mexico that existed for some time before a tax treaty with Mexico was signed to replace it. The short answer is effectively zero, because the tax information exchang

Finance committee  In fairness, let me first of all say that exchange of information has been a component of our tax treaty since before 2006. To be clear, it's the separate identification of TIEAs with non-treaty countries, sometimes termed as tax havens, that is the new element. In relation to

Finance committee  Just to recap the stats, without taking time to list individual country names, we have 90 treaties in force, all of which have an exchange of information provision, and almost all of which are at the current OECD standard and practice. We have 16 more TIEAs in place. We have list

Finance committee  Yes, that's right. Assuming we have all the ones under negotiation signed, sealed, and delivered, so to speak, we wouldn't down tools. I think we'd be looking at others as well. There hasn't been a prioritization exercise set in that respect, but I think we'd take that on. The o