Trump tax reform resulting in massive bills for thousands of Canadian residents
A law meant to hit U.S. corporations sheltering funds offshore is inflicting collateral damage here
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Commenting is now closed for this story.
Stan Cox
This will change the way some wealthy Canadians view the US.
Maybe they'll spend their money at home instead.
Maybe they'll spend their money at home instead.
David Amos
@Stan Cox I crossed paths
with the Toronto lawyer John Richardson and his lawyer pals in BC in
2015 when I filed a lawsuit against the CROWN. They just laughed at me.
Methinks they should Google FATCA, Trump and David Amos N'esy Pas?
Jeremy Kemp
Methinks they should Google FATCA, Trump and David Amos N'esy Pas?
Jeremy Kemp
Americans will shaft anyone if it gives them an advantage,
David Amos
@Jeremy Kemp Oh So True
Stan Cox
If Trump paid any taxes, he might find some surprises in his own returns...
David Amos
@Stan Cox YUP Methinks he should talk to his lawyer Mikey Cohen about FATCA and I ASAP N'esy Pas?
Bill Edward Goate
Trump ran on the platform of massive tax reform and repatriating US cash & jobs. The GOP had majorities in both houses.
Everyone who has dual citizenship or who regularly does business in the US knew this was coming since Nov. 2016 and it came into law in Dec. 2017.
It wasn't exactly a secret. They had more than a year and a half to anticipate, adapt and prepare.
Nothing about this was a surprise, or shouldn't have been to anyone paying attention.
Everyone who has dual citizenship or who regularly does business in the US knew this was coming since Nov. 2016 and it came into law in Dec. 2017.
It wasn't exactly a secret. They had more than a year and a half to anticipate, adapt and prepare.
Nothing about this was a surprise, or shouldn't have been to anyone paying attention.
David Amos
@Bill Edward Goate Methinks FATCA has been around for quite some time N'esy Pas?
Jack Richards
Would be nice if Canada would do the same thing.
David Amos
@Jack Richards Good Point
Mike Mayers
solution: choose 1 nationality and go with that
David Amos
@Mike Mayers Why not just pay taxes in the country you make the money in?
Roger Wilson
Aw Gee, rich athletes have to pay their fair share - Boo Hoo
The 'Progressives' should be happy with this
Bernie would be proud.
The 'Progressives' should be happy with this
Bernie would be proud.
Michele McLean
@Roger Wilson
If the money was earned in Canada, there is no reason at all that the US should get any of the taxes owed on it.
If the money was earned in Canada, there is no reason at all that the US should get any of the taxes owed on it.
Roger Wilson
@Michele McLean
True, but then, that's not the case here.
True, but then, that's not the case here.
David Amos
@Roger Wilson Therein lies the rub
Shane (Wei) Walsh
Good on the USA.
Basically . . . choose one nationality. Are you from the Canada? Are you from the USA? OK. Now pay your taxes to one or the other. Make a decision. 'Nuff said.
Basically . . . choose one nationality. Are you from the Canada? Are you from the USA? OK. Now pay your taxes to one or the other. Make a decision. 'Nuff said.
Michele McLean
@Kathy Altenhofen
Yes, but the tax treaty works against us to siphon duly-owed Canadian taxes into the US by way of the tax credit Canada will be forced to give, no?
Albeit that there wouldn't normally have been enough Canadian tax paid in the first place to off-set this massive tax grab by Trump anyway.
Yes, but the tax treaty works against us to siphon duly-owed Canadian taxes into the US by way of the tax credit Canada will be forced to give, no?
Albeit that there wouldn't normally have been enough Canadian tax paid in the first place to off-set this massive tax grab by Trump anyway.
David Amos
@Michele McLean Obama started the ball rolling
Scott Kane
Trudeau wont investigate the
PANAMA papers but it sounds like Trump is getting the money instead of
Canada. Well done again Liberals LMAO
John Oaktree
@Scott Kane
The Harper Conservatives had the CRA team up with KPMG to create a tax shelter for their rich friends...
The Harper Conservatives had the CRA team up with KPMG to create a tax shelter for their rich friends...
David Amos
@John Oaktree YUP
Stan Cox
If there's one thing that Trump is doing well - he's making Canadians re-consider investing in the US.
David Amos
@Stan Cox YUP
---------- Original message ----------
From: Press <Press@usdoj.gov>
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To: David Amos <motomaniac333@gmail.com>
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---------- Original message ----------
From: Courtney Milbank <cmilbank@bopplaw.com>
Date: Tue, 1 May 2018 13:25:13 +0000
Subject: Automatic reply: RE NAFTA and FATCA I just called Offices the
Solicitor General and Public Affairs U.S. Department of Justice to remind
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To: David Amos <motomaniac333@gmail.com>
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---------- Original message ----------
From: "Eby.MLA, David" <David.Eby.MLA@leg.bc.ca>
Date: Tue, 1 May 2018 13:23:07 +0000
Subject: Automatic reply: RE NAFTA and FATCA I just called Offices the
Solicitor General and Public Affairs U.S. Department of Justice to remind
Mr Francisco and Mr Sessions I am still alive and paying attention
To: David Amos <motomaniac333@gmail.com>
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Need I say that my spelling a grammar make me laugh sometimes?
---------- Original message ----------
From: David Amos <motomaniac333@gmail.com>
Date: Tue, 1 May 2018 09:22:56 -0400
Subject: RE NAFTA and FATCA I just called Offices the Solicitor General and
To: Press@usdoj.gov, SupremeCtBriefs@usdoj.gov, jboppjr@aol.com,
rcoleson@bopplaw.com, cmilbank@bopplaw.com
Cc: David Amos <david.raymond.amos@gmail.com>
"david.eby.mla" <david.eby.mla@leg.bc.ca>
Nobdy can't deny that I have reminds legions of Yankee lawyers about
this old file since 2004 Correct?
https://www.scribd.com/
Need I say that I fund this legal/politcal nonsense interesting today?
https://www.justice.gov/osg/
https://www.justice.gov/sites/
https://www.bopplaw.com/
Noel Francisco
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---------- Original message ----------
From: "MinFinance / FinanceMin (FIN)" <fin.minfinance-financemin.
Date: Tue, 1 May 2018 11:58:55 +0000
Subject: RE: RE NAFTA and FATCA As I read Elizabeth Thompson's article
about Bill Morneau, Trump and the Taxman I wonder if she recalls my
emails or talking to me before and after I ran for seat in the 42nd Parliament?
To: David Amos <motomaniac333@gmail.com>
The Department of Finance acknowledges receipt of your electronic
correspondence. Please be assured that we appreciate receiving your
comments.
Le ministère des Finances accuse réception de votre correspondance
électronique. Soyez assuré(e) que nous apprécions recevoir vos
commentaires.
---------- Original message ----------
From: Kevyn Nightingale <Kevyn.Nightingale@mnp.ca>
Date: Tue, 1 May 2018 11:58:50 +0000
Subject: Automatic reply: RE NAFTA and FATCA As I read Elizabeth
Thompson's article about Bill Morneau, Trump and the Taxman I wonder
if she recalls my emails or talking to me before and after I ran for
seat in the 42nd Parliament?
To: David Amos <motomaniac333@gmail.com>
?I am unavailable until Wednesday. If you need a more immediate
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---------- Original message ----------
From: No-Reply FOR <no-reply@for.is>
Date: Tue, 1 May 2018 11:58:25 +0000
Subject: Forsætisráðuneytið hefur móttekið tölvupóst þinn / Prime
Minister's Office hereby confirms the receipt of your email.
To: David Amos <motomaniac333@gmail.com>
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---------- Original message ----------
From: David Amos <motomaniac333@gmail.com>
Date: Tue, 1 May 2018 07:58:45 -0400
Subject: RE NAFTA and FATCA As I read Elizabeth Thompson's article about Bill Morneau,
Trump and the Taxman I wonder if she recalls my emails or talking to me before and after
I ran for seat in the 42nd Parliament?
To: elizabeth.thompson@cbc.ca, "Bill.Morneau" <Bill.Morneau@canada.ca>,
"mark.vespucci" <mark.vespucci@ci.irs.gov>,
George J Russell TIGTA <j.Russell.George@tigta.treas.
Kraushaar Karen G TIGTA <Karen.Kraushaar@tigta.treas.
"Diane.Lebouthillier" <Diane.Lebouthillier@cra-arc.
"elizabeth.may" <elizabeth.may@parl.gc.ca>, leader <leader@greenparty.ca>,
votejohnrichardson@gmail.com, stephen.kish@camh.ca,
helen.burggraf@odmpublishing.
nmoore <nmoore@bellmedia.ca>, Newsroom <Newsroom@globeandmail.com>, newsonline <newsonline@bbc.co.uk>, news-tips <news-tips@nytimes.com>
Cc: David Amos <david.raymond.amos@gmail.com>
CRA.minister-ministre.ARC@cra-
Philippe.Brideau@cra-arc.gc.ca
beth.webel@ca.pwc.com, postur <postur@for.is>, birgitta <birgitta@this.is>
http://davidraymondamos3.
Tuesday, 1 May 2018
RE FATCA Canada is getting hit harder than other countries by US tax law
http://www.cbc.ca/news/
Trump tax reform resulting in massive bills for thousands of Canadian residents
A law meant to hit U.S. corporations sheltering funds offshore is
inflicting collateral damage here
Elizabeth Thompson · CBC News · Posted: Apr 30, 2018 5:00 PM ET
1000 Comments
Stan Cox
This will change the way some wealthy Canadians view the US.
Maybe they'll spend their money at home instead.
David Amos
@Stan Cox I crossed paths with the Toronto lawyer John Richardson and
his lawyer pals in BC in 2015 when I filed a lawsuit against the
CROWN. They just laughed at me.
Methinks they should Google FATCA, Trump and David Amos N'esy Pas?
http://www.
Anti-FATCA lawsuit plaintiff vows fight against FATCA ‘will go on’
By: Helen Burggraf | 04 Apr 2018
Anti-FATCA lawsuit plaintiff vows fight against FATCA ‘will go on’
One of the seven plaintiffs in a closely-watched lawsuit against the
US Treasury Department over the Foreign Account Tax Compliance Act
that the US Supreme Court on Monday declined to hear has vowed that
the fight against FATCA will go on – in Canada, if nowhere else.
Stephen Kish, pictured left, a professor of Psychiatry and
Pharmacology at the University of Toronto, said on Tuesday that
another lawsuit, involving a Canadian organisation known as the
Alliance for the Defence of Canadian Sovereignty (ADCS), is continuing
against the Canadian government for its “turning over to the US
Internal Revenue Service” information on all those Canadian citizens
whom the US deems to be “US persons” and therefore subject to US tax.
Canada has been providing this information to the US tax authorities
since 2015, as part of an agreement it signed the previous year to
help the US to enforce FATCA – and in so doing avoid potentially
significant financial sanctions that the US would otherwise impose.
As reported, the ADCS’s lawsuit involves two Canadian women who happen
also to be considered to be American citizens by the US, who filed
suit in Canada’s Federal Court in 2014 against the Canadian government
for what they said was its role in enabling the US to come after them
by agreeing to enforce FATCA.
FATCA, which was signed into law in 2010 by President Obama and began
to come into force in 2013, obliges non-US financial institutions
around the world to report to the US Internal Revenue Service on any
accounts they have which are held by American citizens.
To do this, the US has obtained the agreement of foreign governments,
such as Canada’s, to collect the information and pass it on to the
IRS.
As a group Canadians who hold American citizenship, often as a result
of having been born there when their parents were temporarily south of
the border, have been among FATCA’s biggest critics, and even maintain
and contribute to a blog, the Isaac Brock Society, where issues of
concern to them are discussed and relevant news shared. (A gathering
of these “Brockers” is pictured above, at a 2013 anti-FATCA
demonstration in Ottawa in 2013.)
The Alliance for the Defence of Canadian Sovereignty – which Kish, a
Canadian citizen who renounced his American citizenship, chairs – is
funding the Canadian court case. According to the court documents, the
two plantiffs in the case are arguing that the defendants –
essentially the Canadian government, as represented for the purposes
of the lawsuit by the Canadian attorney general and National Revenue
minister – lack the right under Canadian law to provide their
information to the IRS, as they are Canadian citizens and the
information about them which the Canadian government is providing “is
not shown to be relevant for carrying out the provisions” of the laws
currently in force.
Although Canadian citizens, the two plaintiffs, Gwen Deegan and Kazia
Highton, are considered by the US to also be American citizens as well
– and thus having US tax obligations – because they were born there,
even though they left at a young age.
Kish says the expectation is that the case will reach Canada’s Federal
Court “early in 2019”.
Adds Kish: “My hope is that citizens of other countries (eg, England)
who are also regarded by the US, without their consent, to be American
citizens, will also sue their own countries for assisting in the
roundup and turnover of their information to a foreign government, and
the confiscation of their locally-made assets.
“Canada’s argument that it is okay to sacrifice the right of some of
its citizens to prevent a mean-spirited US financial sanction doesn’t
wash.”
As for the US Supreme Court’s decision on Monday not to hear the
matter of Mark Crawford et al v United States Department of the
Treasury, et al, Kish said he was, “as one of the plaintiffs…very
disappointed that our case never actually made it to trial”.
“But hopefully the Republicans Overseas organisation will be
successful in finding other plaintiffs who have suffered a type of
FATCA harm that will survive the Government’s “standing” argument,” he
added, referring to a call by the Republicans’ expat organisation for
seven individuals to be party to another lawsuit.
As reported, the case in which Kish had been involved had been brought
by a group of seven American expatriates as well as Kentucky Senator
Rand Paul. Their argument hinged on their contention that the 2010
FATCA legislation violated their constitutional rights.
However, they lost their case – as of Monday, when the US Supreme
Court declined to hear their challenge to a Sixth Circuit court
decision handed down last August – on grounds that they lacked the
standing to sue, and that the harms they claimed to have suffered as a
result of the law were not, in fact, directly caused by it.
In addition to the US Treasury, the other defendants in that case were
the IRS and the Financial Crimes Enforcement Network.
The Supreme Court petition, Mark Crawford et al v United States
Department of the Treasury, et al, may be viewed on the Treasury’s
website by clicking here.
---------- Forwarded message ----------
From: "MinFinance / FinanceMin (FIN)" <fin.minfinance-financemin.
Date: Wed, 30 Aug 2017 20:48:25 +0000
Subject: RE: Your various correspondence about abusive tax schemes - 2017-02631
To: David Amos <motomaniac333@gmail.com>
The Department of Finance acknowledges receipt of your electronic
correspondence. Please be assured that we appreciate receiving your
comments.
Le ministère des Finances accuse réception de votre correspondance
électronique. Soyez assuré(e) que nous apprécions recevoir vos
commentaires.
---------- Forwarded message ----------
From: Green Party of Canada | Parti vert du Canada <info@greenparty.ca>
Date: Wed, 30 Aug 2017 20:48:45 +0000
Subject: Re: Fwd: Your various correspondence about abusive tax
schemes - 2017-02631
To: David Amos <motomaniac333@gmail.com>
-- Please reply above this line --
http://davidraymondamos3.
Tuesday, 14 February 2017
RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I just got
off the phone with your lawyer Mr Cohen (646-853-0114) Why does he lie
to me after all this time???
---------- Original message ----------
From: "Finance Public / Finance Publique (FIN)"
Date: Tue, 14 Feb 2017 14:52:33 +0000
Subject: RE: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump
I just got off the phone with your lawyer Mr Cohen (646-853-0114) Why
does he lie to me after all this time???
To: David Amos
The Department of Finance acknowledges receipt of your electronic
correspondence. Please be assured that we appreciate receiving your
comments.
Le ministère des Finances accuse réception de votre correspondance
électronique. Soyez assuré(e) que nous apprécions recevoir vos
commentaires.
---------- Original message ----------
From: Póstur FOR
Date: Tue, 14 Feb 2017 14:51:41 +0000
Subject: Re: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump
I just got off the phone with your lawyer Mr Cohen (646-853-0114) Why
does he lie to me after all this time???
To: David Amos
Erindi þitt hefur verið móttekið / Your request has been received
Kveðja / Best regards
Forsætisráðuneytið / Prime Minister's Office
---------- Original message ----------
From: David Amos
Date: Tue, 14 Feb 2017 10:51:14 -0400
Subject: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I
just got off the phone with your lawyer Mr Cohen (646-853-0114) Why
does he lie to me after all this time???
To: president , mdcohen212@gmail.com, pm ,
Pierre-Luc.Dusseault@parl.gc.
B.English@ministers.govt.nz, Malcolm.Turnbull.MP@aph.gov.au
pminvites@pmc.gov.au, mayt@parliament.uk, press , "Andrew.Bailey" ,
fin.financepublic-
"CNN.Viewer.Communications.
Cc: David Amos , elizabeth.thompson@cbc.ca, "justin.ling@vice.com,
elizabeththompson" , djtjr , "Bill.Morneau" , postur ,
stephen.kimber@ukings.ca, "steve.murphy" , "Jacques.Poitras" ,
oldmaison , andre
---------- Original message ----------
From: Michael Cohen
Date: Tue, 14 Feb 2017 14:15:14 +0000
Subject: Automatic reply: RE FATCA ATTN Pierre-Luc.Dusseault I just
called and left a message for you
To: David Amos
Effective January 20, 2017, I have accepted the role as personal
counsel to President Donald J. Trump. All future emails should be
directed to mdcohen212@gmail.com and all future calls should be
directed to 646-853-0114.
______________________________
This communication is from The Trump Organization or an affiliate
thereof and is not sent on behalf of any other individual or entity.
This email may contain information that is confidential and/or
proprietary. Such information may not be read, disclosed, used,
copied, distributed or disseminated except (1) for use by the intended
recipient or (2) as expressly authorized by the sender. If you have
received this communication in error, please immediately delete it and
promptly notify the sender. E-mail transmission cannot be guaranteed
to be received, secure or error-free as emails could be intercepted,
corrupted, lost, destroyed, arrive late, incomplete, contain viruses
or otherwise. The Trump Organization and its affiliates do not
guarantee that all emails will be read and do not accept liability for
any errors or omissions in emails. Any views or opinions presented in
any email are solely those of the author and do not necessarily
represent those of The Trump Organization or any of its
affiliates.Nothing in this communication is intended to operate as an
electronic signature under applicable law.
---------- Original message ----------
From: "Finance Public / Finance Publique (FIN)"
Date: Fri, 10 Feb 2017 22:05:00 +0000
Subject: RE: Yo President Trump RE the Federal Court of Canada File No
T-1557-15 lets see how the media people do with news that is NOT FAKE
To: David Amos
The Department of Finance acknowledges receipt of your electronic
correspondence. Please be assured that we appreciate receiving your
comments.
Le ministère des Finances accuse réception de votre correspondance
électronique. Soyez assuré(e) que nous apprécions recevoir vos
commentaires.
---------- Original message ----------
From: "Hancox, Rick (FCNB)"
Date: Tue, 14 Feb 2017 14:15:22 +0000
Subject: Automatic reply: RE FATCA ATTN Pierre-Luc.Dusseault I just
called and left a message for you
To: David Amos
G'Day/Bonjour,
Thanks for your e-mail. I am out of the office until 24 February. If
you need more immediate assistance, please contact France Bouchard at
506 658-2696.
Je serai absent du bureau jusqu'au 24 fevrier Durant mon absence,
veuillez contacter France Bouchard au 506 658-2696 pour assistance
immédiate.
Thanks/Merci Rick
---------- Forwarded message ----------
From: David Amos
Date: Tue, 27 Oct 2015 20:44:27 -0400
Subject: Fwd: Hey Elizabeth Tompson RE your concrens about the PCO and
the TPP We talked once again yesterday and as usual you were too busy
to listen to me but I also called many of your associates in the
Parliamentry Press Galllery and some did listen to me Correct?
To: gerry@marinerpartners.com, "Stephen.Horsman"
, customerservice@schiffradio.
rjgillis@gmglaw.com, rgfaloon@gmglaw.com, "sally.gomery", ahamilton,
"bruce.northrup", bruce , "bruce.fitch"
Cc: David Amos
---------- Forwarded message ----------
From: David Amos
Date: Sat, 24 Oct 2015 10:13:15 -0400
Subject: Hey Elizabeth Tompson RE your concerns about the PCO and the
TPP We talked once again yesterday and as usual you were too busy to
listen to me but I also called many of your associates in the
Parliamentry Press Galllery and some did listen to me Correct?
To: elizabeththompson@ipolitics.ca
, "justin.trudeau.a1" , "justin.ling" , "rob.moore.a1", jesse
,"thomas.mulcair.a1" , leader, "Jacques.Poitras"
,editor@canadalandshow.com, editor , editor
, "peacock.kurt" news , nbmilk@nbmilk.org, weekesj@bennettjones.com,
mclellana@bennettjones.com, votefast2015@gmail.com,
info@karenmccrimmon.ca, info@marthahallfindlay.ca
Cc: David Amos , "ed.fast", asiskind@newscorp.com, Rupert.Murdoch@fox.com,
shipshore44 , investor@newscorp.com,
Claude.J.G.Levesque@
grant.mccool@thomsonreuters.
newsroom@theguardian.pe.ca, Bob.Kerr@cbc.ca,
Susan.J.Collins@bhpbilliton.
bruce.northrup@gnb.ca, Andrew.Robb.MP@aph.gov.au, gopublic,
"marylou.babineau", policy.karenforcanada@gmail.
ritzg , ritzg , mgeist@uottawa.ca, birgittaj , birgittajoy
Here is a little proof to support what I said on the phone.
A debate
https://www.youtube.com/watch?
and a lawsuit
https://www.scribd.com/doc/
https://www.scribd.com/doc/
FYI During my debates in Fundy Royal I made certain that Rob Moore
and his boss Harper and the Libranos knew within the emails found
below that I was not talking through my hat with reference to the TPP
false promises dairy farmers and my concerns about the Internet
As you journalists well know I made good on my promise to sue the
CROWN while running for a seat in Parliament one last time. As usual
CBC and most of the other very unethical "journlists" ignored the
obvious except Rogers TV and the local reporters employed by the
Irving billionaires
https://www.youtube.com/watch?
Clearly Jesse Brown and his buddy Mean Mikey Geist were yapping about
the TPP before you revealed the PCO's point of view about Harper's
false promise. More importantly to Mean Old Me both those very snobby
and very unethical Upper Canadian spin doctors well aware I knew the
very sneaky Julian Assange long BEFORE he and Birgitta Jonsdotir made
Wikileaks. Hell I have been dicing with the bast Geist for over ten
years since he stuck his nose in Byron Prior's matters (Another matter
no journalist will report about) Anyone can scroll down or just Google
"Michael Geist" "David Amos" or "Julian Assange" "David Amos" to see
the proof of what I say is true.
http://canadalandshow.com/
Katie Jensen • October 12, 2015
Show notes:
University of Ottawa's Michael Geist breaks down the TPP
(Trans-Pacific Partnership), a proposed trade agreement that Stephen
Harper has been toiling over in secret for the last five years - an
agreement that will have huge impacts on Canada's internet freedom and
copyright issues.
Michael Geist's Twitter: @mgeist
I am a law professor at the University of Ottawa where I hold the
Canada Research Chair in Internet and E-commerce Law. My current
contact information is included below:
Address: University of Ottawa
Faculty of Law
Common Law Section
57 Louis Pasteur
Ottawa, ON K1N 6N5
Canada
Phone: (613) 562-5800 extension 3319
Fax: 613-562-5124
E-mail: mgeist@uottawa.ca
Full text of the TPP leak
http://ipolitics.ca/2015/10/
Harper lacks authorities for promised $4.3B TPP farm compensation, PCO admits
By Elizabeth Thompson | Oct 13, 2015 4:20 am | 1 comment |
http://www.cbc.ca/news/
Privy Council Office tracks party promises to prepare for government transition
Senior public servants log and analyze every election promise on a
daily basis to prep briefing books
By Dean Beeby, CBC News Posted: Oct 14, 2015 5:00 AM ET|
http://www.cbc.ca/news/
Liberals, NDP decline PCO offer of confidential briefing on TPP trade deal
Offer to view trade deal just before election rejected as 'political ploy'
CBC News Posted: Oct 15, 2015 5:11 PM ET|
"Mulcair said Trade Minister Ed Fast broke a promise to make all
details of the accord public ahead of election day.
"Instead of openness and transparency, Canadians are learning details
through leaked information and the government's own self-serving
promotional efforts. That's not acceptable," Mulcair said.
The Privy Council Office is the department that provides non-partisan
support to the prime minister and cabinet. The Conservative campaign
told CBC News the government asked the PCO to offer the briefing to
the opposition parties.
But in a separate letter released Thursday, Liberal candidate John
McCallum accused Prime Minister Stephen Harper of continuing a "lack
of transparency" over the deal's details.
"Despite a commitment by the minister of international trade, Mr. Ed
Fast, to release the text of the agreement so all Canadians can judge
it on its merits before election day, media reports this week state
that the details will remain secret," McCallum wrote.
"It is troubling that with just four days remaining until election
day, you continue to refuse to release the text of the agreement for
Canadians to see."
McCallum noted that a previous briefing attended by party
representatives on Oct. 4 "provided no actual details beyond the
limited information already released publicly."
"It is simply not possible to conduct a meaningful, in-depth analysis
of the 1,500-plus page agreement in 90 minutes," he wrote.
I am included in briefing. I was only leader to participate in the 1st
#TPP briefing. #GPC #elxn42 @CanadianGreens @Politicolnews @PnPCBC
— @ElizabethMay
Conservative campaign spokesman Kory Teneycke told CBC News the
Liberals initially agreed to attend the Friday briefing, while the NDP
declined. Teneycke said the briefing was to be based on the chapter
summaries, since the final text does not exist yet.
A Liberal campaign spokesman referred CBC News to McCallum's letter,
but said any suggestion the party had accepted the offer of the
briefing was false."
---------- Forwarded message ----------
From: "Brideau, Philippe" <Philippe.Brideau@cra-arc.gc.
Date: Wed, 9 Sep 2015 03:51:09 +0000
Subject: Automatic reply: Perhaps the Office of Inspector General
(OIG) should review the HARD COPY I sent Stepehn Cutler the General
Counsel of the U.S. Securities and Exchange Commission (SEC) 12 VERY
long years ago?
To: David Amos <motomaniac333@gmail.com>
I am currently away from the office until Monday, September 14. For
assistance, please contact Mylène Croteau at 613-957-3522.
Je suis absent du bureau jusqu'au lundi 14 septembre. Pour
assistance, veuillez communiquer avec Mylène Croteau au 613-957-3522.
---------- Forwarded message ----------
From: "Minister | Ministre (CRA/ARC)" <CRA.minister-ministre.ARC@
Date: Tue, 3 Apr 2018 15:00:59 +0000
Subject: Réponse automatique : RE What is being said about the CRA
today at the Public Interest Hearing in Matter 375 right now
To: David Amos <motomaniac333@gmail.com>
Merci d'avoir écrit à l'honorable Diane Lebouthillier, ministre du
Revenu national. Votre courriel sera lu avec soin et recevra toute
l'attention voulue.
Si votre courriel porte sur une demande de rencontre ou une invitation
à une activité particulière, nous tenons à vous assurer que votre
demande a été notée et transmise à notre adjointe à l'agenda.
***************************
Thank you for writing to the Honourable Diane Lebouthillier, Minister
of National Revenue. Your email will be read with care and will
receive every consideration.
If your email relates to a meeting request or an invitation to a
specific event, please be assured that your request has been noted and
sent to our scheduling assistant.
---------- Original message ----------
From: "Min.Mail / Courrier.Min (CRA/ARC)" <PABMINMAILG@cra-arc.gc.ca>
Date: Wed, 24 May 2017 13:10:52 +0000
Subject: Your various correspondence about abusive tax schemes - 2017-02631
To: "motomaniac333@gmail.com" <motomaniac333@gmail.com>
Mr. David Raymond Amos
motomaniac333@gmail.com
Dear Mr. Amos:
Thank you for your various correspondence about abusive tax schemes,
and for your understanding regarding the delay of this response.
This is an opportunity for me to address your concerns about the way
the Canada Revenue Agency (CRA) deals with aggressive tax planning,
tax avoidance, and tax evasion by targeting individuals and groups
that promote schemes intended to avoid payment of tax. It is also an
opportunity for me to present the Government of Canada’s main
strategies for ensuring fairness for all taxpayers.
The CRA’s mission is to preserve the integrity of Canada’s tax system,
and it is taking concrete and effective action to deal with abusive
tax schemes. Through federal budget funding in 2016 and 2017, the
government has committed close to $1 billion in cracking down on tax
evasion and combatting tax avoidance at home and through the use of
offshore transactions. This additional funding is expected to generate
federal revenues of $2.6 billion over five years for Budget 2016, and
$2.5 billion over five years for Budget 2017.
More precisely, the CRA is cracking down on tax cheats by hiring more
auditors, maintaining its underground economy specialist teams,
increasing coverage of aggressive goods and service tax/harmonized
sales tax planning, increasing coverage of multinational corporations
and wealthy individuals, and taking targeted actions aimed at
promoters of abusive tax schemes.
On the offshore front, the CRA continues to develop tools to improve
its focus on high‑risk taxpayers. It is also considering changes to
its Voluntary Disclosures Program following the first set of program
recommendations received from an independent Offshore Compliance
Advisory Committee. In addition, the CRA is leading international
projects to address the base erosion and profit shifting initiative of
the G20 and the Organisation for Economic Co-operation and
Development, and is collaborating with treaty partners to address the
Panama Papers leaks.
These actions are evidence of the government’s commitment to
protecting tax fairness. The CRA has strengthened its intelligence and
technical capacities for the early detection of abusive tax
arrangements and deterrence of those who participate in them. To
ensure compliance, it has increased the number of actions aimed at
promoters who use illegal schemes. These measures include increased
audits of such promoters, improved information gathering, criminal
investigations where warranted, and better communication with
taxpayers.
To deter potential taxpayer involvement in these schemes, the CRA is
increasing notifications and warnings through its communications
products. It also seeks partnerships with tax preparers, accountants,
and community groups so that they can become informed observers who
can educate their clients.
The CRA will assess penalties against promoters and other
representatives who make false statements involving illegal tax
schemes. The promotion of tax schemes to defraud the government can
lead to criminal investigations, fingerprinting, criminal prosecution,
court fines, and jail time.
Between April 1, 2011, and March 31, 2016, the CRA’s criminal
investigations resulted in the conviction of 42 Canadian taxpayers for
tax evasion with links to money and assets held offshore. In total,
the $34 million in evaded taxes resulted in court fines of $12 million
and 734 months of jail time.
When deciding to pursue compliance actions through the courts, the CRA
consults the Department of Justice Canada to choose an appropriate
solution. Complex tax-related litigation is costly and time consuming,
and the outcome may be unsuccessful. All options to recover amounts
owed are considered.
More specifically, in relation to the KPMG Isle of Man tax avoidance
scheme, publicly available court records show that it is through the
CRA’s efforts that the scheme was discovered. The CRA identified many
of the participants and continues to actively pursue the matter. The
CRA has also identified at least 10 additional tax structures on the
Isle of Man, and is auditing taxpayers in relation to these
structures.
To ensure tax fairness, the CRA commissioned an independent review in
March 2016 to determine if it had acted appropriately concerning KPMG
and its clients. In her review, Ms. Kimberley Brooks, Associate
Professor and former Dean of the Schulich School of Law at Dalhousie
University, examined the CRA’s operational processes and decisions in
relation to the KPMG offshore tax structure and its efforts to obtain
the names of all taxpayers participating in the scheme. Following this
review, the report, released on May 5, 2016, concluded that the CRA
had acted appropriately in its management of the KPMG Isle of Man
file. The report found that the series of compliance measures the CRA
took were in accordance with its policies and procedures. It was
concluded that the procedural actions taken on the KPMG file were
appropriate given the facts of this particular case and were
consistent with the treatment of taxpayers in similar situations. The
report concluded that actions by CRA employees were in accordance with
the CRA’s Code of Integrity and Professional Conduct. There was no
evidence of inappropriate interaction between KPMG and the CRA
employees involved in the case.
Under the CRA’s Code of Integrity and Professional Conduct, all CRA
employees are responsible for real, apparent, or potential conflicts
of interests between their current duties and any subsequent
employment outside of the CRA or the Public Service of Canada.
Consequences and corrective measures play an important role in
protecting the CRA’s integrity.
The CRA takes misconduct very seriously. The consequences of
misconduct depend on the gravity of the incident and its repercussions
on trust both within and outside of the CRA. Misconduct can result in
disciplinary measures up to dismissal.
All forms of tax evasion are illegal. The CRA manages the Informant
Leads Program, which handles leads received from the public regarding
cases of tax evasion across the country. This program, which
coordinates all the leads the CRA receives from informants, determines
whether there has been any non-compliance with tax law and ensures
that the information is examined and conveyed, if applicable, so that
compliance measures are taken. This program does not offer any reward
for tips received.
The new Offshore Tax Informant Program (OTIP) has also been put in
place. The OTIP offers financial compensation to individuals who
provide information related to major cases of offshore tax evasion
that lead to the collection of tax owing. As of December 31, 2016, the
OTIP had received 963 calls and 407 written submissions from possible
informants. Over 218 taxpayers are currently under audit based on
information the CRA received through the OTIP.
With a focus on the highest-risk sectors nationally and
internationally and an increased ability to gather information, the
CRA has the means to target taxpayers who try to hide their income.
For example, since January 2015, the CRA has been collecting
information on all international electronic funds transfers (EFTs) of
$10,000 or more ending or originating in Canada. It is also adopting a
proactive approach by focusing each year on four jurisdictions that
raise suspicion. For the Isle of Man, the CRA audited 3,000 EFTs
totalling $860 million over 12 months and involving approximately 800
taxpayers. Based on these audits, the CRA communicated with
approximately 350 individuals and 400 corporations and performed 60
audits.
In January 2017, I reaffirmed Canada’s important role as a leader for
tax authorities around the world in detecting the structures used for
aggressive tax planning and tax evasion. This is why Canada works
daily with the Joint International Tax Shelter Information Centre
(JITSIC), a network of tax administrations in over 35 countries. The
CRA participates in two expert groups within the JITSIC and leads the
working group on intermediaries and proponents. This ongoing
collaboration is a key component of the CRA’s work to develop strong
relationships with the international community, which will help it
refine the world-class tax system that benefits all Canadians.
The CRA is increasing its efforts and is seeing early signs of
success. Last year, the CRA recovered just under $13 billion as a
result of its audit activities on the domestic and offshore fronts.
Two-thirds of these recoveries are the result of its audit efforts
relating to large businesses and multinational companies.
But there is still much to do, and additional improvements and
investments are underway.
Tax cheats are having a harder and harder time hiding. Taxpayers who
choose to promote or participate in malicious and illegal tax
strategies must face the consequences of their actions. Canadians
expect nothing less. I invite you to read my most recent statement on
this matter at canada.ca/en/revenue-agency/
statement_from_
Thank you for taking the time to write. I hope the information I have
provided is helpful.
Sincerely,
The Honourable Diane Lebouthillier
Minister of National Revenue
From: "MinFinance / FinanceMin (FIN)" <fin.minfinance-financemin.
Date: Tue, 1 May 2018 11:58:55 +0000
Subject: RE: RE NAFTA and FATCA As I read Elizabeth Thompson's article
about Bill Morneau, Trump and the Taxman I wonder if she recalls my
emails or talking to me before and after I ran for seat in the 42nd Parliament?
To: David Amos <motomaniac333@gmail.com>
The Department of Finance acknowledges receipt of your electronic
correspondence. Please be assured that we appreciate receiving your
comments.
Le ministère des Finances accuse réception de votre correspondance
électronique. Soyez assuré(e) que nous apprécions recevoir vos
commentaires.
---------- Original message ----------
From: Kevyn Nightingale <Kevyn.Nightingale@mnp.ca>
Date: Tue, 1 May 2018 11:58:50 +0000
Subject: Automatic reply: RE NAFTA and FATCA As I read Elizabeth
Thompson's article about Bill Morneau, Trump and the Taxman I wonder
if she recalls my emails or talking to me before and after I ran for
seat in the 42nd Parliament?
To: David Amos <motomaniac333@gmail.com>
?I am unavailable until Wednesday. If you need a more immediate
response, please contact rebbecca.lock@mnp.ca
This email and any accompanying attachments contain confidential
information intended only for the individual or entity named above.
Any dissemination or action taken in reliance on this email or
attachments by anyone other than the intended recipient is strictly
prohibited. If you believe you have received this message in error,
please delete it and contact the sender by return email. In compliance
with Canada's Anti-spam legislation (CASL), if you do not wish to
receive further electronic communications from MNP, please reply to
this email with "REMOVE ME" in the subject line."
---------- Original message ----------
From: No-Reply FOR <no-reply@for.is>
Date: Tue, 1 May 2018 11:58:25 +0000
Subject: Forsætisráðuneytið hefur móttekið tölvupóst þinn / Prime
Minister's Office hereby confirms the receipt of your email.
To: David Amos <motomaniac333@gmail.com>
Forsætisráðuneytið hefur móttekið tölvupóst þinn / Prime Minister's
Office hereby confirms the receipt of your email.
Vinsamlega ekki svara þessum tölvupósti, hafið samband í gegnum
for@for.is / Do not reply to this email. Contact us with any queries
via for@for.is
Með bestu kveðju / Best regards
------------------------------
Forsætisráðuneytið / Prime Minister's Office
Stjórnarráðshúsinu, IS - 101 Reykjavík, Sími/Tel. +354 545 8400
www.stjornarradid.is -
Fyrirvari/Disclaimer<http://
---------- Original message ----------
From: David Amos <motomaniac333@gmail.com>
Date: Tue, 1 May 2018 07:58:45 -0400
Subject: RE NAFTA and FATCA As I read Elizabeth Thompson's article about Bill Morneau,
Trump and the Taxman I wonder if she recalls my emails or talking to me before and after
I ran for seat in the 42nd Parliament?
To: elizabeth.thompson@cbc.ca, "Bill.Morneau" <Bill.Morneau@canada.ca>,
"mark.vespucci" <mark.vespucci@ci.irs.gov>,
George J Russell TIGTA <j.Russell.George@tigta.treas.
Kraushaar Karen G TIGTA <Karen.Kraushaar@tigta.treas.
"Diane.Lebouthillier" <Diane.Lebouthillier@cra-arc.
"elizabeth.may" <elizabeth.may@parl.gc.ca>, leader <leader@greenparty.ca>,
votejohnrichardson@gmail.com, stephen.kish@camh.ca,
helen.burggraf@odmpublishing.
nmoore <nmoore@bellmedia.ca>, Newsroom <Newsroom@globeandmail.com>, newsonline <newsonline@bbc.co.uk>, news-tips <news-tips@nytimes.com>
Cc: David Amos <david.raymond.amos@gmail.com>
CRA.minister-ministre.ARC@cra-
Philippe.Brideau@cra-arc.gc.ca
beth.webel@ca.pwc.com, postur <postur@for.is>, birgitta <birgitta@this.is>
http://davidraymondamos3.
Tuesday, 1 May 2018
RE FATCA Canada is getting hit harder than other countries by US tax law
http://www.cbc.ca/news/
Trump tax reform resulting in massive bills for thousands of Canadian residents
A law meant to hit U.S. corporations sheltering funds offshore is
inflicting collateral damage here
Elizabeth Thompson · CBC News · Posted: Apr 30, 2018 5:00 PM ET
1000 Comments
Stan Cox
This will change the way some wealthy Canadians view the US.
Maybe they'll spend their money at home instead.
David Amos
@Stan Cox I crossed paths with the Toronto lawyer John Richardson and
his lawyer pals in BC in 2015 when I filed a lawsuit against the
CROWN. They just laughed at me.
Methinks they should Google FATCA, Trump and David Amos N'esy Pas?
http://www.
Anti-FATCA lawsuit plaintiff vows fight against FATCA ‘will go on’
By: Helen Burggraf | 04 Apr 2018
Anti-FATCA lawsuit plaintiff vows fight against FATCA ‘will go on’
One of the seven plaintiffs in a closely-watched lawsuit against the
US Treasury Department over the Foreign Account Tax Compliance Act
that the US Supreme Court on Monday declined to hear has vowed that
the fight against FATCA will go on – in Canada, if nowhere else.
Stephen Kish, pictured left, a professor of Psychiatry and
Pharmacology at the University of Toronto, said on Tuesday that
another lawsuit, involving a Canadian organisation known as the
Alliance for the Defence of Canadian Sovereignty (ADCS), is continuing
against the Canadian government for its “turning over to the US
Internal Revenue Service” information on all those Canadian citizens
whom the US deems to be “US persons” and therefore subject to US tax.
Canada has been providing this information to the US tax authorities
since 2015, as part of an agreement it signed the previous year to
help the US to enforce FATCA – and in so doing avoid potentially
significant financial sanctions that the US would otherwise impose.
As reported, the ADCS’s lawsuit involves two Canadian women who happen
also to be considered to be American citizens by the US, who filed
suit in Canada’s Federal Court in 2014 against the Canadian government
for what they said was its role in enabling the US to come after them
by agreeing to enforce FATCA.
FATCA, which was signed into law in 2010 by President Obama and began
to come into force in 2013, obliges non-US financial institutions
around the world to report to the US Internal Revenue Service on any
accounts they have which are held by American citizens.
To do this, the US has obtained the agreement of foreign governments,
such as Canada’s, to collect the information and pass it on to the
IRS.
As a group Canadians who hold American citizenship, often as a result
of having been born there when their parents were temporarily south of
the border, have been among FATCA’s biggest critics, and even maintain
and contribute to a blog, the Isaac Brock Society, where issues of
concern to them are discussed and relevant news shared. (A gathering
of these “Brockers” is pictured above, at a 2013 anti-FATCA
demonstration in Ottawa in 2013.)
The Alliance for the Defence of Canadian Sovereignty – which Kish, a
Canadian citizen who renounced his American citizenship, chairs – is
funding the Canadian court case. According to the court documents, the
two plantiffs in the case are arguing that the defendants –
essentially the Canadian government, as represented for the purposes
of the lawsuit by the Canadian attorney general and National Revenue
minister – lack the right under Canadian law to provide their
information to the IRS, as they are Canadian citizens and the
information about them which the Canadian government is providing “is
not shown to be relevant for carrying out the provisions” of the laws
currently in force.
Although Canadian citizens, the two plaintiffs, Gwen Deegan and Kazia
Highton, are considered by the US to also be American citizens as well
– and thus having US tax obligations – because they were born there,
even though they left at a young age.
Kish says the expectation is that the case will reach Canada’s Federal
Court “early in 2019”.
Adds Kish: “My hope is that citizens of other countries (eg, England)
who are also regarded by the US, without their consent, to be American
citizens, will also sue their own countries for assisting in the
roundup and turnover of their information to a foreign government, and
the confiscation of their locally-made assets.
“Canada’s argument that it is okay to sacrifice the right of some of
its citizens to prevent a mean-spirited US financial sanction doesn’t
wash.”
As for the US Supreme Court’s decision on Monday not to hear the
matter of Mark Crawford et al v United States Department of the
Treasury, et al, Kish said he was, “as one of the plaintiffs…very
disappointed that our case never actually made it to trial”.
“But hopefully the Republicans Overseas organisation will be
successful in finding other plaintiffs who have suffered a type of
FATCA harm that will survive the Government’s “standing” argument,” he
added, referring to a call by the Republicans’ expat organisation for
seven individuals to be party to another lawsuit.
As reported, the case in which Kish had been involved had been brought
by a group of seven American expatriates as well as Kentucky Senator
Rand Paul. Their argument hinged on their contention that the 2010
FATCA legislation violated their constitutional rights.
However, they lost their case – as of Monday, when the US Supreme
Court declined to hear their challenge to a Sixth Circuit court
decision handed down last August – on grounds that they lacked the
standing to sue, and that the harms they claimed to have suffered as a
result of the law were not, in fact, directly caused by it.
In addition to the US Treasury, the other defendants in that case were
the IRS and the Financial Crimes Enforcement Network.
The Supreme Court petition, Mark Crawford et al v United States
Department of the Treasury, et al, may be viewed on the Treasury’s
website by clicking here.
---------- Forwarded message ----------
From: "MinFinance / FinanceMin (FIN)" <fin.minfinance-financemin.
Date: Wed, 30 Aug 2017 20:48:25 +0000
Subject: RE: Your various correspondence about abusive tax schemes - 2017-02631
To: David Amos <motomaniac333@gmail.com>
The Department of Finance acknowledges receipt of your electronic
correspondence. Please be assured that we appreciate receiving your
comments.
Le ministère des Finances accuse réception de votre correspondance
électronique. Soyez assuré(e) que nous apprécions recevoir vos
commentaires.
---------- Forwarded message ----------
From: Green Party of Canada | Parti vert du Canada <info@greenparty.ca>
Date: Wed, 30 Aug 2017 20:48:45 +0000
Subject: Re: Fwd: Your various correspondence about abusive tax
schemes - 2017-02631
To: David Amos <motomaniac333@gmail.com>
-- Please reply above this line --
http://davidraymondamos3.
Tuesday, 14 February 2017
RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I just got
off the phone with your lawyer Mr Cohen (646-853-0114) Why does he lie
to me after all this time???
---------- Original message ----------
From: "Finance Public / Finance Publique (FIN)"
Date: Tue, 14 Feb 2017 14:52:33 +0000
Subject: RE: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump
I just got off the phone with your lawyer Mr Cohen (646-853-0114) Why
does he lie to me after all this time???
To: David Amos
The Department of Finance acknowledges receipt of your electronic
correspondence. Please be assured that we appreciate receiving your
comments.
Le ministère des Finances accuse réception de votre correspondance
électronique. Soyez assuré(e) que nous apprécions recevoir vos
commentaires.
---------- Original message ----------
From: Póstur FOR
Date: Tue, 14 Feb 2017 14:51:41 +0000
Subject: Re: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump
I just got off the phone with your lawyer Mr Cohen (646-853-0114) Why
does he lie to me after all this time???
To: David Amos
Erindi þitt hefur verið móttekið / Your request has been received
Kveðja / Best regards
Forsætisráðuneytið / Prime Minister's Office
---------- Original message ----------
From: David Amos
Date: Tue, 14 Feb 2017 10:51:14 -0400
Subject: RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I
just got off the phone with your lawyer Mr Cohen (646-853-0114) Why
does he lie to me after all this time???
To: president , mdcohen212@gmail.com, pm ,
Pierre-Luc.Dusseault@parl.gc.
B.English@ministers.govt.nz, Malcolm.Turnbull.MP@aph.gov.au
pminvites@pmc.gov.au, mayt@parliament.uk, press , "Andrew.Bailey" ,
fin.financepublic-
"CNN.Viewer.Communications.
Cc: David Amos , elizabeth.thompson@cbc.ca, "justin.ling@vice.com,
elizabeththompson" , djtjr , "Bill.Morneau" , postur ,
stephen.kimber@ukings.ca, "steve.murphy" , "Jacques.Poitras" ,
oldmaison , andre
---------- Original message ----------
From: Michael Cohen
Date: Tue, 14 Feb 2017 14:15:14 +0000
Subject: Automatic reply: RE FATCA ATTN Pierre-Luc.Dusseault I just
called and left a message for you
To: David Amos
Effective January 20, 2017, I have accepted the role as personal
counsel to President Donald J. Trump. All future emails should be
directed to mdcohen212@gmail.com and all future calls should be
directed to 646-853-0114.
______________________________
This communication is from The Trump Organization or an affiliate
thereof and is not sent on behalf of any other individual or entity.
This email may contain information that is confidential and/or
proprietary. Such information may not be read, disclosed, used,
copied, distributed or disseminated except (1) for use by the intended
recipient or (2) as expressly authorized by the sender. If you have
received this communication in error, please immediately delete it and
promptly notify the sender. E-mail transmission cannot be guaranteed
to be received, secure or error-free as emails could be intercepted,
corrupted, lost, destroyed, arrive late, incomplete, contain viruses
or otherwise. The Trump Organization and its affiliates do not
guarantee that all emails will be read and do not accept liability for
any errors or omissions in emails. Any views or opinions presented in
any email are solely those of the author and do not necessarily
represent those of The Trump Organization or any of its
affiliates.Nothing in this communication is intended to operate as an
electronic signature under applicable law.
---------- Original message ----------
From: "Finance Public / Finance Publique (FIN)"
Date: Fri, 10 Feb 2017 22:05:00 +0000
Subject: RE: Yo President Trump RE the Federal Court of Canada File No
T-1557-15 lets see how the media people do with news that is NOT FAKE
To: David Amos
The Department of Finance acknowledges receipt of your electronic
correspondence. Please be assured that we appreciate receiving your
comments.
Le ministère des Finances accuse réception de votre correspondance
électronique. Soyez assuré(e) que nous apprécions recevoir vos
commentaires.
---------- Original message ----------
From: "Hancox, Rick (FCNB)"
Date: Tue, 14 Feb 2017 14:15:22 +0000
Subject: Automatic reply: RE FATCA ATTN Pierre-Luc.Dusseault I just
called and left a message for you
To: David Amos
G'Day/Bonjour,
Thanks for your e-mail. I am out of the office until 24 February. If
you need more immediate assistance, please contact France Bouchard at
506 658-2696.
Je serai absent du bureau jusqu'au 24 fevrier Durant mon absence,
veuillez contacter France Bouchard au 506 658-2696 pour assistance
immédiate.
Thanks/Merci Rick
---------- Forwarded message ----------
From: David Amos
Date: Tue, 27 Oct 2015 20:44:27 -0400
Subject: Fwd: Hey Elizabeth Tompson RE your concrens about the PCO and
the TPP We talked once again yesterday and as usual you were too busy
to listen to me but I also called many of your associates in the
Parliamentry Press Galllery and some did listen to me Correct?
To: gerry@marinerpartners.com, "Stephen.Horsman"
, customerservice@schiffradio.
rjgillis@gmglaw.com, rgfaloon@gmglaw.com, "sally.gomery", ahamilton,
"bruce.northrup", bruce , "bruce.fitch"
Cc: David Amos
---------- Forwarded message ----------
From: David Amos
Date: Sat, 24 Oct 2015 10:13:15 -0400
Subject: Hey Elizabeth Tompson RE your concerns about the PCO and the
TPP We talked once again yesterday and as usual you were too busy to
listen to me but I also called many of your associates in the
Parliamentry Press Galllery and some did listen to me Correct?
To: elizabeththompson@ipolitics.ca
, "justin.trudeau.a1" , "justin.ling" , "rob.moore.a1", jesse
,"thomas.mulcair.a1" , leader, "Jacques.Poitras"
,editor@canadalandshow.com, editor , editor
, "peacock.kurt" news , nbmilk@nbmilk.org, weekesj@bennettjones.com,
mclellana@bennettjones.com, votefast2015@gmail.com,
info@karenmccrimmon.ca, info@marthahallfindlay.ca
Cc: David Amos , "ed.fast", asiskind@newscorp.com, Rupert.Murdoch@fox.com,
shipshore44 , investor@newscorp.com,
Claude.J.G.Levesque@
grant.mccool@thomsonreuters.
newsroom@theguardian.pe.ca, Bob.Kerr@cbc.ca,
Susan.J.Collins@bhpbilliton.
bruce.northrup@gnb.ca, Andrew.Robb.MP@aph.gov.au, gopublic,
"marylou.babineau", policy.karenforcanada@gmail.
ritzg , ritzg , mgeist@uottawa.ca, birgittaj , birgittajoy
Here is a little proof to support what I said on the phone.
A debate
https://www.youtube.com/watch?
and a lawsuit
https://www.scribd.com/doc/
https://www.scribd.com/doc/
FYI During my debates in Fundy Royal I made certain that Rob Moore
and his boss Harper and the Libranos knew within the emails found
below that I was not talking through my hat with reference to the TPP
false promises dairy farmers and my concerns about the Internet
As you journalists well know I made good on my promise to sue the
CROWN while running for a seat in Parliament one last time. As usual
CBC and most of the other very unethical "journlists" ignored the
obvious except Rogers TV and the local reporters employed by the
Irving billionaires
https://www.youtube.com/watch?
Clearly Jesse Brown and his buddy Mean Mikey Geist were yapping about
the TPP before you revealed the PCO's point of view about Harper's
false promise. More importantly to Mean Old Me both those very snobby
and very unethical Upper Canadian spin doctors well aware I knew the
very sneaky Julian Assange long BEFORE he and Birgitta Jonsdotir made
Wikileaks. Hell I have been dicing with the bast Geist for over ten
years since he stuck his nose in Byron Prior's matters (Another matter
no journalist will report about) Anyone can scroll down or just Google
"Michael Geist" "David Amos" or "Julian Assange" "David Amos" to see
the proof of what I say is true.
http://canadalandshow.com/
Katie Jensen • October 12, 2015
Show notes:
University of Ottawa's Michael Geist breaks down the TPP
(Trans-Pacific Partnership), a proposed trade agreement that Stephen
Harper has been toiling over in secret for the last five years - an
agreement that will have huge impacts on Canada's internet freedom and
copyright issues.
Michael Geist's Twitter: @mgeist
I am a law professor at the University of Ottawa where I hold the
Canada Research Chair in Internet and E-commerce Law. My current
contact information is included below:
Address: University of Ottawa
Faculty of Law
Common Law Section
57 Louis Pasteur
Ottawa, ON K1N 6N5
Canada
Phone: (613) 562-5800 extension 3319
Fax: 613-562-5124
E-mail: mgeist@uottawa.ca
Full text of the TPP leak
http://ipolitics.ca/2015/10/
Harper lacks authorities for promised $4.3B TPP farm compensation, PCO admits
By Elizabeth Thompson | Oct 13, 2015 4:20 am | 1 comment |
http://www.cbc.ca/news/
Privy Council Office tracks party promises to prepare for government transition
Senior public servants log and analyze every election promise on a
daily basis to prep briefing books
By Dean Beeby, CBC News Posted: Oct 14, 2015 5:00 AM ET|
http://www.cbc.ca/news/
Liberals, NDP decline PCO offer of confidential briefing on TPP trade deal
Offer to view trade deal just before election rejected as 'political ploy'
CBC News Posted: Oct 15, 2015 5:11 PM ET|
"Mulcair said Trade Minister Ed Fast broke a promise to make all
details of the accord public ahead of election day.
"Instead of openness and transparency, Canadians are learning details
through leaked information and the government's own self-serving
promotional efforts. That's not acceptable," Mulcair said.
The Privy Council Office is the department that provides non-partisan
support to the prime minister and cabinet. The Conservative campaign
told CBC News the government asked the PCO to offer the briefing to
the opposition parties.
But in a separate letter released Thursday, Liberal candidate John
McCallum accused Prime Minister Stephen Harper of continuing a "lack
of transparency" over the deal's details.
"Despite a commitment by the minister of international trade, Mr. Ed
Fast, to release the text of the agreement so all Canadians can judge
it on its merits before election day, media reports this week state
that the details will remain secret," McCallum wrote.
"It is troubling that with just four days remaining until election
day, you continue to refuse to release the text of the agreement for
Canadians to see."
McCallum noted that a previous briefing attended by party
representatives on Oct. 4 "provided no actual details beyond the
limited information already released publicly."
"It is simply not possible to conduct a meaningful, in-depth analysis
of the 1,500-plus page agreement in 90 minutes," he wrote.
I am included in briefing. I was only leader to participate in the 1st
#TPP briefing. #GPC #elxn42 @CanadianGreens @Politicolnews @PnPCBC
— @ElizabethMay
Conservative campaign spokesman Kory Teneycke told CBC News the
Liberals initially agreed to attend the Friday briefing, while the NDP
declined. Teneycke said the briefing was to be based on the chapter
summaries, since the final text does not exist yet.
A Liberal campaign spokesman referred CBC News to McCallum's letter,
but said any suggestion the party had accepted the offer of the
briefing was false."
---------- Forwarded message ----------
From: "Brideau, Philippe" <Philippe.Brideau@cra-arc.gc.
Date: Wed, 9 Sep 2015 03:51:09 +0000
Subject: Automatic reply: Perhaps the Office of Inspector General
(OIG) should review the HARD COPY I sent Stepehn Cutler the General
Counsel of the U.S. Securities and Exchange Commission (SEC) 12 VERY
long years ago?
To: David Amos <motomaniac333@gmail.com>
I am currently away from the office until Monday, September 14. For
assistance, please contact Mylène Croteau at 613-957-3522.
Je suis absent du bureau jusqu'au lundi 14 septembre. Pour
assistance, veuillez communiquer avec Mylène Croteau au 613-957-3522.
---------- Forwarded message ----------
From: "Minister | Ministre (CRA/ARC)" <CRA.minister-ministre.ARC@
Date: Tue, 3 Apr 2018 15:00:59 +0000
Subject: Réponse automatique : RE What is being said about the CRA
today at the Public Interest Hearing in Matter 375 right now
To: David Amos <motomaniac333@gmail.com>
Merci d'avoir écrit à l'honorable Diane Lebouthillier, ministre du
Revenu national. Votre courriel sera lu avec soin et recevra toute
l'attention voulue.
Si votre courriel porte sur une demande de rencontre ou une invitation
à une activité particulière, nous tenons à vous assurer que votre
demande a été notée et transmise à notre adjointe à l'agenda.
***************************
Thank you for writing to the Honourable Diane Lebouthillier, Minister
of National Revenue. Your email will be read with care and will
receive every consideration.
If your email relates to a meeting request or an invitation to a
specific event, please be assured that your request has been noted and
sent to our scheduling assistant.
---------- Original message ----------
From: "Min.Mail / Courrier.Min (CRA/ARC)" <PABMINMAILG@cra-arc.gc.ca>
Date: Wed, 24 May 2017 13:10:52 +0000
Subject: Your various correspondence about abusive tax schemes - 2017-02631
To: "motomaniac333@gmail.com" <motomaniac333@gmail.com>
Mr. David Raymond Amos
motomaniac333@gmail.com
Dear Mr. Amos:
Thank you for your various correspondence about abusive tax schemes,
and for your understanding regarding the delay of this response.
This is an opportunity for me to address your concerns about the way
the Canada Revenue Agency (CRA) deals with aggressive tax planning,
tax avoidance, and tax evasion by targeting individuals and groups
that promote schemes intended to avoid payment of tax. It is also an
opportunity for me to present the Government of Canada’s main
strategies for ensuring fairness for all taxpayers.
The CRA’s mission is to preserve the integrity of Canada’s tax system,
and it is taking concrete and effective action to deal with abusive
tax schemes. Through federal budget funding in 2016 and 2017, the
government has committed close to $1 billion in cracking down on tax
evasion and combatting tax avoidance at home and through the use of
offshore transactions. This additional funding is expected to generate
federal revenues of $2.6 billion over five years for Budget 2016, and
$2.5 billion over five years for Budget 2017.
More precisely, the CRA is cracking down on tax cheats by hiring more
auditors, maintaining its underground economy specialist teams,
increasing coverage of aggressive goods and service tax/harmonized
sales tax planning, increasing coverage of multinational corporations
and wealthy individuals, and taking targeted actions aimed at
promoters of abusive tax schemes.
On the offshore front, the CRA continues to develop tools to improve
its focus on high‑risk taxpayers. It is also considering changes to
its Voluntary Disclosures Program following the first set of program
recommendations received from an independent Offshore Compliance
Advisory Committee. In addition, the CRA is leading international
projects to address the base erosion and profit shifting initiative of
the G20 and the Organisation for Economic Co-operation and
Development, and is collaborating with treaty partners to address the
Panama Papers leaks.
These actions are evidence of the government’s commitment to
protecting tax fairness. The CRA has strengthened its intelligence and
technical capacities for the early detection of abusive tax
arrangements and deterrence of those who participate in them. To
ensure compliance, it has increased the number of actions aimed at
promoters who use illegal schemes. These measures include increased
audits of such promoters, improved information gathering, criminal
investigations where warranted, and better communication with
taxpayers.
To deter potential taxpayer involvement in these schemes, the CRA is
increasing notifications and warnings through its communications
products. It also seeks partnerships with tax preparers, accountants,
and community groups so that they can become informed observers who
can educate their clients.
The CRA will assess penalties against promoters and other
representatives who make false statements involving illegal tax
schemes. The promotion of tax schemes to defraud the government can
lead to criminal investigations, fingerprinting, criminal prosecution,
court fines, and jail time.
Between April 1, 2011, and March 31, 2016, the CRA’s criminal
investigations resulted in the conviction of 42 Canadian taxpayers for
tax evasion with links to money and assets held offshore. In total,
the $34 million in evaded taxes resulted in court fines of $12 million
and 734 months of jail time.
When deciding to pursue compliance actions through the courts, the CRA
consults the Department of Justice Canada to choose an appropriate
solution. Complex tax-related litigation is costly and time consuming,
and the outcome may be unsuccessful. All options to recover amounts
owed are considered.
More specifically, in relation to the KPMG Isle of Man tax avoidance
scheme, publicly available court records show that it is through the
CRA’s efforts that the scheme was discovered. The CRA identified many
of the participants and continues to actively pursue the matter. The
CRA has also identified at least 10 additional tax structures on the
Isle of Man, and is auditing taxpayers in relation to these
structures.
To ensure tax fairness, the CRA commissioned an independent review in
March 2016 to determine if it had acted appropriately concerning KPMG
and its clients. In her review, Ms. Kimberley Brooks, Associate
Professor and former Dean of the Schulich School of Law at Dalhousie
University, examined the CRA’s operational processes and decisions in
relation to the KPMG offshore tax structure and its efforts to obtain
the names of all taxpayers participating in the scheme. Following this
review, the report, released on May 5, 2016, concluded that the CRA
had acted appropriately in its management of the KPMG Isle of Man
file. The report found that the series of compliance measures the CRA
took were in accordance with its policies and procedures. It was
concluded that the procedural actions taken on the KPMG file were
appropriate given the facts of this particular case and were
consistent with the treatment of taxpayers in similar situations. The
report concluded that actions by CRA employees were in accordance with
the CRA’s Code of Integrity and Professional Conduct. There was no
evidence of inappropriate interaction between KPMG and the CRA
employees involved in the case.
Under the CRA’s Code of Integrity and Professional Conduct, all CRA
employees are responsible for real, apparent, or potential conflicts
of interests between their current duties and any subsequent
employment outside of the CRA or the Public Service of Canada.
Consequences and corrective measures play an important role in
protecting the CRA’s integrity.
The CRA takes misconduct very seriously. The consequences of
misconduct depend on the gravity of the incident and its repercussions
on trust both within and outside of the CRA. Misconduct can result in
disciplinary measures up to dismissal.
All forms of tax evasion are illegal. The CRA manages the Informant
Leads Program, which handles leads received from the public regarding
cases of tax evasion across the country. This program, which
coordinates all the leads the CRA receives from informants, determines
whether there has been any non-compliance with tax law and ensures
that the information is examined and conveyed, if applicable, so that
compliance measures are taken. This program does not offer any reward
for tips received.
The new Offshore Tax Informant Program (OTIP) has also been put in
place. The OTIP offers financial compensation to individuals who
provide information related to major cases of offshore tax evasion
that lead to the collection of tax owing. As of December 31, 2016, the
OTIP had received 963 calls and 407 written submissions from possible
informants. Over 218 taxpayers are currently under audit based on
information the CRA received through the OTIP.
With a focus on the highest-risk sectors nationally and
internationally and an increased ability to gather information, the
CRA has the means to target taxpayers who try to hide their income.
For example, since January 2015, the CRA has been collecting
information on all international electronic funds transfers (EFTs) of
$10,000 or more ending or originating in Canada. It is also adopting a
proactive approach by focusing each year on four jurisdictions that
raise suspicion. For the Isle of Man, the CRA audited 3,000 EFTs
totalling $860 million over 12 months and involving approximately 800
taxpayers. Based on these audits, the CRA communicated with
approximately 350 individuals and 400 corporations and performed 60
audits.
In January 2017, I reaffirmed Canada’s important role as a leader for
tax authorities around the world in detecting the structures used for
aggressive tax planning and tax evasion. This is why Canada works
daily with the Joint International Tax Shelter Information Centre
(JITSIC), a network of tax administrations in over 35 countries. The
CRA participates in two expert groups within the JITSIC and leads the
working group on intermediaries and proponents. This ongoing
collaboration is a key component of the CRA’s work to develop strong
relationships with the international community, which will help it
refine the world-class tax system that benefits all Canadians.
The CRA is increasing its efforts and is seeing early signs of
success. Last year, the CRA recovered just under $13 billion as a
result of its audit activities on the domestic and offshore fronts.
Two-thirds of these recoveries are the result of its audit efforts
relating to large businesses and multinational companies.
But there is still much to do, and additional improvements and
investments are underway.
Tax cheats are having a harder and harder time hiding. Taxpayers who
choose to promote or participate in malicious and illegal tax
strategies must face the consequences of their actions. Canadians
expect nothing less. I invite you to read my most recent statement on
this matter at canada.ca/en/revenue-agency/
statement_from_
Thank you for taking the time to write. I hope the information I have
provided is helpful.
Sincerely,
The Honourable Diane Lebouthillier
Minister of National Revenue
Trump tax reform resulting in massive bills for thousands of Canadian residents
A law meant to hit U.S. corporations sheltering funds offshore is inflicting collateral damage here
Thousands of Canadian residents are
facing massive tax bills because of U.S. President Donald Trump's
December tax reform, CBC News has learned.
Canadian residents with U.S. or dual citizenship who own Canadian corporations are being slapped by an American measure meant to get big U.S. multinationals to stop parking billions of dollars in offshore subsidiaries — a one-time retroactive tax being levied on all of their companies' retained earnings going back to 1986.
Tax lawyers and accountants say they are struggling to find strategies to soften the blow of what one of them calls a "nightmare" situation for their clients.
Mark Feigenbaum, who specializes in tax law and accounting, said hundreds of his clients — including celebrities and professional athletes who set up Canadian companies to handle their endorsement revenue — are facing bills of "several hundreds of thousands of dollars, if not more than a million."
It's all because of the 1,097-page Tax Cuts and Jobs Act, described as the most significant tax overhaul in the United States since 1986.
When Trump signed the bill into law on Dec. 22, he boasted that it was going to "bring back probably $4 trillion from overseas.
"Who would object to trillions of dollars being brought back into our country?"
The act includes a "repatriation tax" meant to apply to the previously untaxed earnings of American firms' foreign subsidiaries. Major multinationals like Apple have been accused for years of parking profits in offshore subsidiaries to avoid paying billions of dollars in U.S. tax.
But the way the legislation was drafted has inadvertently hit Canadian residents with U.S. or dual citizenship and a Canadian corporation.
While the tax is based on a company's retained earnings, it's the person with U.S. citizenship who has to pay it. That means some might be forced to withdraw money from their Canadian companies in order to pay the U.S. tax, which would trigger a higher tax bill in Canada.
Kevyn Nightingale, a partner in the MNP accounting firm, says Canada is getting hit harder than other countries by the tax law.
Some
experts — like Kevyn Nightingale, a partner in the accounting firm
MNP — said Canada is being hit harder than other countries because of
the large number of U.S. citizens living in Canada, and because Canadian
tax rules have made incorporation an attractive option over the years.
"Canada happens to have a very high level of self-employment and incorporated self-employed people," said Nightingale, adding that "thousands" of his firm's clients have been affected by the tax measure. "So that makes the problem bigger in Canada, probably, than anywhere else.
"For many of my clients, it's a disaster. Unfortunately, they are collateral damage in what I think overall is a very good tax move by the United States."
Some of those being hit are like retired Queens University professor and doctor Brian Arthur — professionals or small business operators who were using corporations to save for retirement. Arthur, a dual Canadian-American citizen, estimates the new tax will cost him between $200,000 and $300,000.
"We have spent our years planning for retirement and saving money and now it's a mess," he said.
Arthur likely will have to sell investments held by his company to pay the tax. He risks having to pay Canadian income tax on the money once he transfers it out of the company.
Vancouver residents Suzanne and Ted Herman are facing a six-figure tax bill as a result of President Trump's tax reform. (CBC)
In
Vancouver, Suzanne and Ted Herman are facing a similar tax bill. Now in
their 60s, like Arthur, they have been using their company Lemonade
Films to save for their retirement.
"We're not sleeping nights," said Suzanne Herman. "We discuss our options and none of them are good."
Others are looking at tax bills that run into the millions, said Beth Webel, a partner in tax services with the accounting firm PwC Canada.
"Another one came through yesterday at $4 million and I'm aware of one that's around $22 million," she said. "So, if you've got a very successful business that has been accumulating profits for a long time, the bill can be very high."
The problem, says Toronto lawyer John Richardson, is that the law was written so broadly it's hitting a lot of small players along with the giant corporations piling up money abroad.
"The legislation ... literally means all of these people in Canada who are deemed to be U.S. citizens under U.S. law – and understand that most of these are just Canadian citizens living in Canada – are all of a sudden … required to include in their income for 2017 all of the retained earnings of their Canadian-controlled private corporations going back to 1986," he said.
Toronto lawyer John Richardson says the Trump administration law was written too broadly. (John Richardson)
The more prudent you have been in building up a nest egg in your company, the bigger the tax bite, said Richardson.
"How would you like it if you had been careful with your money for 30-35 years ... just to have it yanked out from under you?"
Because the retained earnings have to be declared on an individual's 2017 tax return, and the tax reform was signed into law so late in the year, experts say those affected had no chance to take steps to lessen their tax exposure.
The IRS, meanwhile, has been scrambling to clarify the new rules. Those affected originally had to file their returns by April 15; they have now have until June 15. They can also elect to pay the tax over eight years.
"Even the IRS doesn't know fully how to administer this tax," said Nightingale. "They have been issuing guidance piece after guidance piece since January in order to explain to people how these things are supposed to apply."
For Canadians, ignoring the new tax and hoping the IRS doesn't notice probably isn't a good idea.
Under the Foreign Account Tax Compliance Act (FATCA), Canadian banks and financial institutions have been asking their customers and account holders whether they are U.S. persons for tax purposes for the past few years. They forward that information to the Canada Revenue Agency, which turns it over to the IRS.
Several experts said they expect a spike in the number of Canadian residents renouncing their U.S. citizenship as a result of the tax — but add that it's too late to avoid the repatriation tax.
A second tax contained in the tax reform is going to hit U.S. citizens with Canadian corporations going forward. The Global Intangible Low Tax Income tax (GILTI) will be imposed on annual income earned by "controlled foreign corporations" such as those registered in Canada.
Dan Lauzon, spokesman for Finance Minister Bill Morneau, said the federal government is studying the Trump administration's tax reform.
"The Department of Finance is conducting detailed analytical work to consider the impact of U.S. tax reform," said Lauzon. "This work is expected to take several months."
Meanwhile, Lauzon said those affected by the tax reform should consult a professional familiar with U.S. tax law.
Officials from the U.S. Embassy referred CBC News' questions to the U.S. Treasury Department, which has not yet responded.
Beth Webel, partner, tax services with the accounting firm PwC: "Somebody's got to give some relief here." (PwC)
Webel said the Canadian government should look to the Canada-U.S. tax treaty for possible solutions.
"Usually when you have double tax, we would go to the Canada-U.S. (tax) treaty and say somehow, somebody's got to give some relief here."
Richardson said the new tax violates the spirit of that treaty.
"The government of Canada absolutely needs to get involved in this because this is not only the protection of Canadian citizens, this is protecting the economic sovereignty of Canada.
"You can't let another country come in and raid the country's pension plans."
Elizabeth Thompson can be reached at elizabeth.thompson@cbc.ca
Canadian residents with U.S. or dual citizenship who own Canadian corporations are being slapped by an American measure meant to get big U.S. multinationals to stop parking billions of dollars in offshore subsidiaries — a one-time retroactive tax being levied on all of their companies' retained earnings going back to 1986.
Tax lawyers and accountants say they are struggling to find strategies to soften the blow of what one of them calls a "nightmare" situation for their clients.
Mark Feigenbaum, who specializes in tax law and accounting, said hundreds of his clients — including celebrities and professional athletes who set up Canadian companies to handle their endorsement revenue — are facing bills of "several hundreds of thousands of dollars, if not more than a million."
It's all because of the 1,097-page Tax Cuts and Jobs Act, described as the most significant tax overhaul in the United States since 1986.
When Trump signed the bill into law on Dec. 22, he boasted that it was going to "bring back probably $4 trillion from overseas.
"Who would object to trillions of dollars being brought back into our country?"
Repatriating corporate profits
The act includes a "repatriation tax" meant to apply to the previously untaxed earnings of American firms' foreign subsidiaries. Major multinationals like Apple have been accused for years of parking profits in offshore subsidiaries to avoid paying billions of dollars in U.S. tax.
But the way the legislation was drafted has inadvertently hit Canadian residents with U.S. or dual citizenship and a Canadian corporation.
While the tax is based on a company's retained earnings, it's the person with U.S. citizenship who has to pay it. That means some might be forced to withdraw money from their Canadian companies in order to pay the U.S. tax, which would trigger a higher tax bill in Canada.
'It's a disaster'
"Canada happens to have a very high level of self-employment and incorporated self-employed people," said Nightingale, adding that "thousands" of his firm's clients have been affected by the tax measure. "So that makes the problem bigger in Canada, probably, than anywhere else.
"For many of my clients, it's a disaster. Unfortunately, they are collateral damage in what I think overall is a very good tax move by the United States."
Some of those being hit are like retired Queens University professor and doctor Brian Arthur — professionals or small business operators who were using corporations to save for retirement. Arthur, a dual Canadian-American citizen, estimates the new tax will cost him between $200,000 and $300,000.
"We have spent our years planning for retirement and saving money and now it's a mess," he said.
Arthur likely will have to sell investments held by his company to pay the tax. He risks having to pay Canadian income tax on the money once he transfers it out of the company.
"We're not sleeping nights," said Suzanne Herman. "We discuss our options and none of them are good."
Others are looking at tax bills that run into the millions, said Beth Webel, a partner in tax services with the accounting firm PwC Canada.
"Another one came through yesterday at $4 million and I'm aware of one that's around $22 million," she said. "So, if you've got a very successful business that has been accumulating profits for a long time, the bill can be very high."
The problem, says Toronto lawyer John Richardson, is that the law was written so broadly it's hitting a lot of small players along with the giant corporations piling up money abroad.
'Yanked out from under'
"The legislation ... literally means all of these people in Canada who are deemed to be U.S. citizens under U.S. law – and understand that most of these are just Canadian citizens living in Canada – are all of a sudden … required to include in their income for 2017 all of the retained earnings of their Canadian-controlled private corporations going back to 1986," he said.
"How would you like it if you had been careful with your money for 30-35 years ... just to have it yanked out from under you?"
Because the retained earnings have to be declared on an individual's 2017 tax return, and the tax reform was signed into law so late in the year, experts say those affected had no chance to take steps to lessen their tax exposure.
The IRS, meanwhile, has been scrambling to clarify the new rules. Those affected originally had to file their returns by April 15; they have now have until June 15. They can also elect to pay the tax over eight years.
"Even the IRS doesn't know fully how to administer this tax," said Nightingale. "They have been issuing guidance piece after guidance piece since January in order to explain to people how these things are supposed to apply."
Under the Foreign Account Tax Compliance Act (FATCA), Canadian banks and financial institutions have been asking their customers and account holders whether they are U.S. persons for tax purposes for the past few years. They forward that information to the Canada Revenue Agency, which turns it over to the IRS.
Several experts said they expect a spike in the number of Canadian residents renouncing their U.S. citizenship as a result of the tax — but add that it's too late to avoid the repatriation tax.
A second tax contained in the tax reform is going to hit U.S. citizens with Canadian corporations going forward. The Global Intangible Low Tax Income tax (GILTI) will be imposed on annual income earned by "controlled foreign corporations" such as those registered in Canada.
Dan Lauzon, spokesman for Finance Minister Bill Morneau, said the federal government is studying the Trump administration's tax reform.
"The Department of Finance is conducting detailed analytical work to consider the impact of U.S. tax reform," said Lauzon. "This work is expected to take several months."
Applying the tax treaty
Meanwhile, Lauzon said those affected by the tax reform should consult a professional familiar with U.S. tax law.
Officials from the U.S. Embassy referred CBC News' questions to the U.S. Treasury Department, which has not yet responded.
"Usually when you have double tax, we would go to the Canada-U.S. (tax) treaty and say somehow, somebody's got to give some relief here."
Richardson said the new tax violates the spirit of that treaty.
"The government of Canada absolutely needs to get involved in this because this is not only the protection of Canadian citizens, this is protecting the economic sovereignty of Canada.
"You can't let another country come in and raid the country's pension plans."
Elizabeth Thompson can be reached at elizabeth.thompson@cbc.ca
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