Questions and responses 41st Parliament, 1st session June 2, 2011, to September 13, 2013

With regard to information supplied in 2009 by the Government of France to the Government of Canada regarding secret bank accounts in Switzerland: (a) how many Canadians have been identified as having undeclared bank accounts outside of Canada; (b) what action, if any, has been taken by Canadian officials to recover unpaid taxes associated with Canadians' undeclared bank accounts outside of Canada; (c) how many identified Canadians have availed themselves of the Voluntary Disclosure Program (VDP) with the Canada Revenue Agency (CRA); (d) how many identified Canadian accounts have settled with the CRA; (e) how much money has the CRA assessed as a result of investigating these secret banks accounts outside of Canada (i) in unpaid taxes, (ii) in interest, (iii) in fines, (iv) in penalties; (f) how much of the money in (e) has been collected; (g) how many of the cases are under appeal; (h) how many cases remain open; (i) how many more cases does the CRA anticipate will be opened; (j) how many cases have been closed (i.e. the full amount of taxes, interest, fines and penalties have been collected); (k) how much money was collected from the cases in (j) (i) in unpaid taxes, (ii) in interest, (iii) in fines, (iv) in penalties; (l) how many account holders in the cases have made partial payment; (m) of the partial payments made (i) what was the largest amount, (ii) what was the smallest amount, (iii) what was the average amount; (n) of the amounts of money contained in the secret accounts declared or discovered by CRA (i) what was the largest amount, (ii) what was the smallest amount, (iii) what was the average amount; (o) on what date did the CRA become aware of the names of Canadians with accounts outside of Canada that were obtained by the Government of France; (p) on what dates did CRA begin its investigations; (q) on what date did the first audit of an individual account holder begin; (r) how many of the identified Canadians with bank accounts outside of Canada (i) have had their account(s) audited, (ii) have had their account(s) reassessed, (iii) have been the subject of a compliance action; (s) how many of the identified Canadians with bank accounts outside of Canada (i) have not had their account(s) audited, (ii) have not had their account(s) reassessed, (iii) have not been the subject of a compliance action; (t) how many tax evasion charges were laid; and (u) has the Government of Canada made any changes to the VDP in the past 24 months?

With regard to possible tax evasion in Liechtenstein as of March 23, 2012: (a) since receiving the names of 106 Canadians with accounts in Liechtenstein, have any other Canadians been identified as having undeclared bank accounts in Liechtenstein, and, in total, how many Canadians have now been identified as having undeclared bank accounts in Liechtenstein; (b) what actions have been taken by Canadian officials to recover unpaid taxes associated with Canadians' undeclared bank accounts in Liechtenstein; (c) how many identified Canadians have availed themselves of the Voluntary Disclosure Program with the Canada Revenue Agency (CRA); (d) how many identified Canadian accounts have settled with the CRA; (e) how much money has the CRA assessed as a result of investigating these secret bank accounts in Liechtenstein in (i) unpaid taxes, (ii) interest, (iii) fines, (iv) penalties; (f) how much of the money in (e) has been collected; (g) how many of the cases are under appeal; (h) how many cases remain open; (i) how many more cases does the CRA anticipate will be opened; (j) how many cases have been closed (i.e., the full amount of taxes, interest, fines and penalties have been collected); (k) how much money in (j) has been collected in (i) unpaid taxes, (ii) interest, (iii) fines, (iv) penalties; (l) how many account holders in the cases have made a partial payment; (m) of the partial payments made, what was the (i) largest amount, (ii) smallest amount, (iii) average amount; (n) how much does the CRA has yet to collect in (i) taxes, (ii) interest, (iii) fines, (iv) penalties; (o) of the amounts of money contained in the Liechtenstein accounts declared to or discovered by CRA, what was the (i) largest amount, (ii) smallest amount, (iii) average amount; (p) how many of the identified Canadians with bank accounts in Liechtenstein (i) have had their accounts audited, (ii) have had their accounts reassessed, (iii) have been the subject of a compliance action; (q) how many of the identified Canadians with bank accounts in Liechtenstein (i) have not had their accounts audited, (ii) have not had their accounts reassessed, (iii) have not been the subject of a compliance action; and (r) how many tax evasion charges have been laid?

With regard to overseas tax evasion for the period from February 6, 2006 to September 30, 2012: (a) how many Canadians have been identified as having undeclared overseas bank accounts; (b) how many accounts have been identified; (c) how many identified Canadians have availed themselves of the Voluntary Disclosure Program (VDP) with the Canada Revenue Agency (CRA); (d) how many identified Canadian accounts have settled with the CRA; (e) how much money has the CRA assessed as a result of investigating these secret overseas bank accounts (i) in unpaid taxes, (ii) in interest, (iii) in fines, (iv) in penalties; (f) how much of the money in (e) has been collected; (g) how many of the cases are under appeal; (h) how many cases remain open; (i) how many more cases does the CRA anticipate will be opened; (j) how many cases have been closed (i.e. the full amount of taxes, interest, fines and penalties has been collected); (k) how much money in (j) has been collected (i) in unpaid taxes, (ii) in interest, (iii) in fines, (iv) in penalties; (l) how many account holders in the cases have made partial payment; (m) of the partial payments made, (i) what was the largest amount, (ii) what was the smallest amount, (iii) what was the average amount; (n) how much does the CRA anticipate it has yet to collect (i) in taxes, (ii) in interest, (iii) in fines, (iv) in penalties; (o) of the amounts of money contained in overseas accounts declared or discovered by CRA (i) what was the largest amount, (ii) what was the smallest amount, (iii) what was the average amount; (p) how many of the identified Canadians with overseas bank accounts (i) have had their account(s) audited, (ii) have had their account(s) reassessed, (iii) have been the subject of a compliance action; (q) how many of the identified Canadians with overseas bank accounts (i) have not had their account(s) audited, (ii) have not had their account(s) reassessed, (iii) have not been the subject of a compliance action; (r) how many tax evasion charges were laid; (s) has the government made any changes to the VDP in the past 24 months; (t) how many Canadians have been convicted of tax evasion; and (u) how many Canadians have been convicted of tax evasion related to money and other assets held overseas?

With regard to Canadians discovered to have secret bank accounts in Liechtenstein: (a) since the government received the names of 106 Canadians with accounts in Liechtenstein, how many of the 106 have made an application under the Voluntary Disclosure Program (VDP) and how many of these VDP disclosures have been accepted; (b) who authorized these disclosures after the Canada Revenue Agency (CRA) had already declared these Canadians ineligible for the VDP; (c) does the CRA accept disclosures that do not meet its guidelines for disclosures under the VDP; (d) how many times has the CRA allowed ineligible individuals to make disclosures under the VDP in the past (i) 6 months, (ii) year, (iii) 5 years; (e) what policy or procedures exist that govern whether or not an ordinarily ineligible disclosure will be accepted; (f) does the CRA make exceptions to the VDP for individuals who are suspected of domestic tax evasion; and (g) what percentage of individuals who disclose information to the CRA through the VDP are (i) fined, (ii) penalized, (iii) prosecuted, (iv) convicted of tax evasion, (v) placed under house arrest, (vi) sent to prison?

With regard to information supplied by the government of France to the government of Canada regarding secret bank accounts and possible tax evasion in Switzerland as of March 23, 2012: (a) since the government received the names of 1800 Canadians with bank accounts in Switzerland, have any other Canadians been identified as having undeclared bank accounts in Switzerland, and, in total, how many Canadians have now been identified as having undeclared bank accounts in Switzerland; (b) what actions have been taken by Canadian officials to recover unpaid taxes associated with Canadians' undeclared bank accounts in Switzerland; (c) how many identified Canadians have availed themselves of the Voluntary Disclosure Program (VDP) with the Canada Revenue Agency (CRA); (d) how many identified Canadian accounts have settled with the CRA; (e) how much money has the CRA assessed as a result of investigating these secret banks accounts in Switzerland in (i) unpaid taxes, (ii) interest, (iii) fines, (iv) penalties; (f) how much of the money in (e) has been collected; (g) how many of the cases are under appeal; (h) how many cases remain open; (i) how many more cases does the CRA anticipate will be opened; (j) how many cases have been closed (i.e., the full amount of taxes, interest, fines and penalties have been collected); (k) how much money in (j) has been collected in (i) unpaid taxes, (ii) interest, (iii) fines, (iv) penalties; (l) how many account holders in the cases have made a partial payment; (m) of the partial payments made, what was the (i) largest amount, (ii) smallest amount, (iii) average amount; (n) how much does the CRA have yet to collect in (i) taxes, (ii) interest, (iii) fines, (iv) penalties; (o) of the amounts of money contained in the Switzerland accounts declared or discovered by the CRA, what was the (i) largest amount, (ii) smallest amount, (iii) average amount; (p) on what date was the CRA first made aware of the names of Canadians with accounts in Switzerland; (q) on what date did the CRA begin its investigation; (r) on what date did the first audit of an individual account holder begin; (s) how many of the identified Canadians with bank accounts in Switzerland have (i) had their account or accounts audited, (ii) had their account or accounts reassessed, (iii) been the subject of a compliance action; (t) how many of the identified Canadians with bank accounts in Switzerland (i) have not had their account or accounts audited, (ii) have not had their account or accounts reassessed, (iii) have not been the subject of a compliance action; and (u) how many tax evasion charges have been laid?

With regard to the Canada Revenue Agency’s (CRA) responses to the provisions of the Internal Revenue Service (IRS) regarding the Report of Foreign Bank and Financial Accounts (FBAR): (a) according to the government’s analysis, do the IRS provisions comply with the provisions of the Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital and its amending Protocol (2007); (b) are there Canadian exemptions to FBAR; (c) has Canada negotiated the FBAR provisions with United States Treasury Officials or the IRS, (i) at what time was the government made aware of these provisions, (ii) how long did it take for Canada to respond to the changes made by the IRS and the United States Treasury; (d) how will the government ensure that the CRA does not act on behalf of the IRS to collect revenues and penalties; (e) has Canada informed dual citizens about their tax obligations resulting from FBAR; (f) what was the number of exchanges of information between Canada and the United States of America this year and during the past ten years regarding FBAR, (i) has the CRA set internal deadlines to be able to respond to exchange of information requests in a timely manner, (ii) will Canada work to improve bilateral cooperation on this issue, (iii) has there been an increase of exchange of information requests at the CRA due to FBAR; (g) will the government lose revenue as a result of the implementation of FBAR; (h) what are the cost implications emanating from FBAR (i) for the government, (ii) for the CRA, (iii) for Canadian banks, (iv) who will absorb these costs, (v) are there other types of non-financial costs such as efficiency or fairness reductions; (i) how many complaints has the CRA received regarding FBAR or related vexatious inquiries by the IRS, (i) what are the main complaints, (ii) what has the CRA done concerning these complaints, (iii) what department at the CRA is in charge of dealing with complaints of this nature, (iv) will the CRA cut Full-Time Equivalents from that department or reduce its funding, (v) has the office of the Taxpayers’ Ombudsman looked into the matter; (j) will FBAR prevent double taxation of pre-migration gain; (k) has there been an increase in arbitration cases due to active procedures by the IRS, (i) what departments are most affected, (ii) has the CRA cut Full-Time Equivalents from each of these affected departments or reduced their funding; (l) will FBAR affect different saving vehicles such as, but not limited to, (i) Registered Retirement Savings Plans, (ii) Registered Education Savings Plans, (iii) Registered Disability Savings Plans, (iv) Tax-Free Savings Accounts; and (m) how many Canadian-American dual citizens are affected by FBAR and does Canada have contact information for the dual citizens affected by FBAR?

With regard to the Canada Revenue Agency’s (CRA) response to the provisions of the Internal Revenue Service (IRS) regarding the Foreign Account Tax Compliance Act (FATCA): (a) according to the government’s analysis, do the FATCA provisions comply with the provisions of the Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital and its amending Protocol (2007); (b) how many citizens from the United States of America will be affected by FATCA, (ii) are there specific Canadian exemptions to FATCA; (c) has Canada negotiated with United States Treasury officials or the IRS following the announcement of FATCA provisions, (i) at what time was the government made aware of these provisions, (ii) how long did it take Canada to respond to the initial creation of FATCA and its implementation, (iii) are there ongoing negotiations in this regard; (d) will Canada inform dual citizens about FATCA and, if so, (i) how, (ii) at what time, (iii) what department or agencies will be responsible; (e) has the government conducted any studies or mandated a task force to look into how much FATCA will cost Canadians and, if so, what are the cost implications resulting from the additional regulations and demands, (i) for the government, (ii) for the CRA, (iii) for Canadian banks, (iv) who will absorb these costs, (v) are there other types of non-financial costs such as efficiency or fairness reductions; (f) which Canadian civil liberties associations or other types of association has the government met with to discuss the privacy implications of FATCA and what actions will the government undertake to protect the fundamental civil liberties of all Canadians in this regard; (g) according to the government’s analysis, do the FATCA provisions comply with the provisions of the Privacy Act or the Personal Information Protection and Electronic Documents Act, and if so, which department undertook this assesment; (h) in order to discuss the implications of FATCA, who within the government has met with (i) Canadian banks, (ii) other financial institutions, (iii) insurance companies; (i) how many complaints has the CRA received regarding FATCA, (i) what are the main complaints, (ii) what has the CRA done concerning these complaints, (iii) what department at the CRA is in charge of dealing with complaints of this nature, (iv) will the CRA cut Full-Time Equivalents from that department or reduce its funding, (v) has the office of the Taxpayers’ Ombudsman looked into the matter; (j) has Canada ever studied the development or implementation of a process similar to FATCA to improve tax compliance involving foreign financial assets and offshore accounts; (k) who will be most affected by FATCA and have concerns been raised by entities such as, but not limited to, (i) interests groups, (ii) stakeholder groups, (iii) hedge funds; and (l) will FATCA affect different saving vehicles such as, but not limited to, (i) Registered Retirement Savings Plans, (ii) Registered Education Savings Plans, (iii) Registered Disability Savings Plans, (iv) Tax-Free Savings Accounts?