Finance committee  The only thing I would add is that it gets even more complicated when you have a firm like KPMG with an affiliate law firm. Generally speaking, accountants don't enjoy this privilege, but often their opinions and their plans are attached to what lawyers say, and then things get h

Finance committee  I will try. I think the most important effort Canada is participating in is the OECD common reporting standard for the automatic exchange of cross-border tax information.

Finance committee  That's a very good point. I didn't say this, but it's a very tricky matter to go after these folks. Most countries do a lousy job. I sometimes say that the Americans get the tip of the iceberg, but at least they're getting the tip. The U.S. has a very aggressive reputation, with

Finance committee  I'm not aware of any concrete information. My sense is that the Americans traditionally were much more funded, and then again, they have this vast army of the DEA, ICE, Customs, the FBI, and so on that assist with tracking down tax cheats and international money launderers. But

Finance committee  I think the answer is clear. In our country it would be unconstitutional to require lawyers to rat on their clients. We had a case last year—

Finance committee  It would be contrary to our rules of professional obligation to reveal confidential information. There was a case last year, the Federation of Law Societies of Canada versus the Queen, where it was held to be unconstitutional to require lawyers to report some client information

Finance committee  Yes, and to return quickly to your earlier comments, when I teach tax law I tell my students that, if they have an RRSP, they are engaged in tax avoidance—that is a registered retirement savings plan, like many of your constituents have, presumably. That is legal, but your consti

Finance committee  Sure. Thank you. It's a very boring academic article, but thank you for bringing attention to it.

Finance committee  There is an estimated $10 trillion to $35 trillion hidden offshore in tax havens. When we look at the empirical research by economists in this area, we see money moving all around the world. It typically comes from middle-income, developing countries that are quasi-democratic or

Finance committee  Yes, it's a more recent concern that tax haven conduits are being used to facilitate terrorist financing. I'm working on a paper—I have a grant for that—with Christian Leuprecht. We're putting together some research in that area. The traditional concerns are offshore tax evasion

Finance committee  Tax law is interesting in how one is supposed to interpret it. All of this goes back to an old English case called Duke of Westminster, where the House of Lords told us that we could govern our affairs as we saw fit to avoid taxes as long as we complied with the letter of the law

Finance committee  Merci. There are thousands of settled cases between CRA and taxpayers each year. I don't know any data offhand concerning that. In terms of aggressive offshore tax avoidance or tax evasion, again I don't have any data, but it's not unusual for the government to enter into a c

Finance committee  Again, I began on a very positive note, but in my writings I've been quite critical of the CRA, at least in the last 20 years, ramping up to 2013. One of the problems was revealed in the Liechtenstein leak. That came from 2007, where there were over 100 Canadian taxpayers with u

Finance committee  Absolutely. I think that was a very positive legislative change. I think it was budget 2013 when that came about. I just think of the famous UBS Geneva case. There was a U.S. Senate investigation that revealed Canadians had stored in this one bank $5 billion offshore. We've never

Finance committee  Mr. Chair, ladies and gentlemen, good morning. Thank you again for inviting me to appear before this committee. Though I've had the opportunity or privilege in the past to appear on a number of occasions, I thought I'd introduce myself to the committee members because only Mr.