While I was publishing this in my blog the lawyer Bobby Baby Kennedy called
back from
(416) 846-6598 and played as dumb. Hell he even claimed that he
did not know
who Frank McKenna was No partner even a lowly collection
dude within Dentons is allowed to be THAT
stupid.
Simon A. Fish
General Counsel, BMO Financial Group
Simon Fish is General Counsel of BMO Financial Group.
Mr. Fish is responsible for the overall legal affairs of the bank
including the compliance, corporate security and corporate secretarial functions.
In addition, Mr. Fish oversees the bank’s ethics and privacy, ombudsman
and corporate sustainability functions. His responsibilities include mergers
and acquisitions, securities and banking regulation, corporate governance and
complex litigation. He serves as counsel to the office of the Chairman and
the Board of Directors. He is a member of the bank’s Management Committee.
Mr. Fish joined BMO from Vale Inco where he served as Executive Vice-President
and General Counsel. Prior to that he was Vice-President, General Counsel and
Corporate Secretary of Shell Canada. Before joining Shell, Mr. Fish practiced
corporate and securities law with an international law firm. He holds undergraduate
and masters degrees in business and law.
Mr. Fish serves on the boards of a number of non-profit and charitable organizations.
Corporate Secretary's Department
Bank of Montreal
100 King Street
West
1 First Canadian Place, 21st Floor
Toronto, ON M5X 1A1
Tel:
416-867-6785
Fax: 416-867-6793
Email: corp.secretary@bmo.com
To
contact Investor Relations at Bank of Montreal:
Investor
Relations
Bank of Montreal
100 King Street West
1 First Canadian Place,
10th Floor
Toronto, ON M5X 1A1
Tel: 416-867-4770
Fax:
416-867-3367
Email: investor.relations@bmo.com>
ONTARIO SUPERIOR COURT OF JUSTICE
COMMERCIAL LIST
IN THE MATTER OF THE COMPANIES’ CREDITORS ARRANGEMENT ACT,
R.S.C. 1985, c. C-36, AS AMENDED
AND IN THE MATTER OF A PLAN OF COMPROMISE OR ARRANGEMENT OF
FIRSTONSITE G.P. INC.
SERVICE LIST
https://www.dentons.com/en/robert-kennedy
Rob (Robert) J. Kennedy
Robert is a member of the Insolvency and Restructuring Group in both the
Calgary and Toronto offices where he advises on insolvency and
corporate restructuring matters under the CCAA, BIA and the Business Corporations Act.
In addition to restructuring matters, Robert has experience in
receiverships, security enforcement, debt collection, and forbearance
arrangements. He represents lenders, debtors, receivers, trustees,
monitors and DIP lenders.
Robert
J. Kennedy
Direct: 416-367-6756
Email: robert.kennedy@dentons.com
>
---------- Forwarded message ----------
> From: David Amos motomaniac333@gmail.com
>
Date: Mon, 12 Jun 2017 09:32:09 -0400
> Subject: Attn Integrity
Commissioner Alexandre Deschênes, Q.C.,
> To: coi@gnb.ca
> Cc: david.raymond.amos@gmail.com
>
>
Good Day Sir
>
> After I heard you speak on CBC I called your office
again and managed
> to speak to one of your staff for the first
time
>
> Please find attached the documents I promised to send to
the lady who
> answered the phone this morning. Please notice that not
after the Sgt
> at Arms took the documents destined to your office his pal
Tanker
> Malley barred me in writing with an "English" only
document.
>
> These are the hearings and the dockets in Federal
Court that I
> suggested that you study closely.
>
> This is
the docket in Federal Court
>
> http://cas-cdc-www02.cas-satj.gc.ca/IndexingQueries/infp_RE_info_e.php?court_no=T-1557-15&select_court=T
>
>
These are digital recordings of the last three hearings
>
> Dec
14th https://archive.org/details/BahHumbug
>
>
January 11th, 2016 https://archive.org/details/Jan11th2015
>
>
April 3rd, 2017
>
> https://archive.org/details/April32017JusticeLeblancHearing
>
>
>
This is the docket in the Federal Court of Appeal
>
> http://cas-cdc-www02.cas-satj.gc.ca/IndexingQueries/infp_RE_info_e.php?court_no=A-48-16&select_court=All
>
>
>
The only hearing thus far
>
> May 24th, 2017
>
> https://archive.org/details/May24thHoedown
>
>
>
This Judge understnds the meaning of the word Integrity
>
> Date:
20151223
>
> Docket: T-1557-15
>
> Fredericton, New
Brunswick, December 23, 2015
>
> PRESENT: The Honourable Mr.
Justice Bell
>
> BETWEEN:
>
> DAVID RAYMOND
AMOS
>
> Plaintiff
>
> and
>
> HER MAJESTY
THE QUEEN
>
> Defendant
>
> ORDER
>
>
(Delivered orally from the Bench in Fredericton, New Brunswick, on
>
December 14, 2015)
>
> The Plaintiff seeks an appeal de novo, by way
of motion pursuant to
> the Federal Courts Rules (SOR/98-106), from an
Order made on November
> 12, 2015, in which Prothonotary Morneau struck
the Statement of Claim
> in its entirety.
>
> At the outset of
the hearing, the Plaintiff brought to my attention a
> letter dated
September 10, 2004, which he sent to me, in my then
> capacity as Past
President of the New Brunswick Branch of the Canadian
> Bar Association,
and the then President of the Branch, Kathleen Quigg,
> (now a Justice of
the New Brunswick Court of Appeal). In that letter
> he
stated:
>
> As for your past President, Mr. Bell, may I suggest that
you check the
> work of Frank McKenna before I sue your entire law firm
including you.
> You are your brother’s keeper.
>
> Frank
McKenna is the former Premier of New Brunswick and a former
> colleague of
mine at the law firm of McInnes Cooper. In addition to
> expressing an
intention to sue me, the Plaintiff refers to a number of
> people in his
Motion Record who he appears to contend may be witnesses
> or potential
parties to be added. Those individuals who are known to
> me personally,
include, but are not limited to the former Prime
> Minister of Canada, The
Right Honourable Stephen Harper; former
> Attorney General of Canada and
now a Justice of the Manitoba Court of
> Queen’s Bench, Vic Toews; former
member of Parliament Rob Moore;
> former Director of Policing Services,
the late Grant Garneau; former
> Chief of the Fredericton Police Force,
Barry McKnight; former Staff
> Sergeant Danny Copp; my former colleagues
on the New Brunswick Court
> of Appeal, Justices Bradley V. Green and
Kathleen Quigg, and, retired
> Assistant Commissioner Wayne Lang of the
Royal Canadian Mounted
> Police.
>
> In the circumstances,
given the threat in 2004 to sue me in my
> personal capacity and my past
and present relationship with many
> potential witnesses and/or potential
parties to the litigation, I am
> of the view there would be a reasonable
apprehension of bias should I
> hear this motion. See Justice de
Grandpré’s dissenting judgment in
> Committee for Justice and Liberty et
al v National Energy Board et al,
> [1978] 1 SCR 369 at p 394 for the
applicable test regarding
> allegations of bias. In the circumstances,
although neither party has
> requested I recuse myself, I consider it
appropriate that I do so.
>
>
> AS A RESULT OF MY RECUSAL,
THIS COURT ORDERS that the Administrator of
> the Court schedule another
date for the hearing of the motion. There
> is no order as to
costs.
>
> “B. Richard Bell”
> Judge
>
>
>
Below after the CBC article about your concerns (I made one comment
>
already) you will find the text of just two of many emails I had sent
> to
your office over the years since I first visited it in 2006.
>
> I
noticed that on July 30, 2009, he was appointed to the the Court
>
Martial Appeal Court of Canada Perhaps you should scroll to the
> bottom
of this email ASAP and read the entire Paragraph 83 of my
> lawsuit now
before the Federal Court of Canada?
>
> "FYI This is the text of the
lawsuit that should interest Trudeau the most
>
>
> ----------
Original message ----------
> From: justin.trudeau.a1@parl.gc.ca
>
Date: Thu, Oct 22, 2015 at 8:18 PM
> Subject: Réponse automatique : RE My
complaint against the CROWN in
> Federal Court Attn David Hansen and Peter
MacKay If you planning to
> submit a motion for a publication ban on my
complaint trust that you
> dudes are way past too late
> To: david.raymond.amos@gmail.com
>
>
Veuillez noter que j'ai changé de courriel. Vous pouvez me rejoindre à
>
lalanthier@hotmail.com
>
>
Pour rejoindre le bureau de M. Trudeau veuillez envoyer un courriel à
> tommy.desfosses@parl.gc.ca
>
>
Please note that I changed email address, you can reach me at
> lalanthier@hotmail.com
>
>
To reach the office of Mr. Trudeau please send an email to
> tommy.desfosses@parl.gc.ca
>
>
Thank you,
>
> Merci ,
>
>
> http://davidraymondamos3.blogspot.ca/2015/09/v-behaviorurldefaultvmlo.html
>
>
>
83. The Plaintiff states that now that Canada is involved in more war
>
in Iraq again it did not serve Canadian interests and reputation to
>
allow Barry Winters to publish the following words three times over
> five
years after he began his bragging:
>
> January 13, 2015
> This
Is Just AS Relevant Now As When I wrote It During The Debate
>
>
December 8, 2014
> Why Canada Stood Tall!
>
> Friday, October
3, 2014
> Little David Amos’ “True History Of War” Canadian Airstrikes
And
> Stupid Justin Trudeau
>
> Canada’s and Canadians free
ride is over. Canada can no longer hide
> behind Amerka’s and NATO’s
skirts.
>
> When I was still in Canadian Forces then Prime Minister
Jean Chretien
> actually committed the Canadian Army to deploy in the
second campaign
> in Iraq, the Coalition of the Willing. This was against
or contrary to
> the wisdom or advice of those of us Canadian officers
that were
> involved in the initial planning phases of that operation.
There were
> significant concern in our planning cell, and NDHQ about of
the dearth
> of concern for operational guidance, direction, and forces
for
> operations after the initial occupation of Iraq. At the “last
minute”
> Prime Minister Chretien and the Liberal government changed its
mind.
> The Canadian government told our amerkan cousins that we would
not
> deploy combat troops for the Iraq campaign, but would deploy
a
> Canadian Battle Group to Afghanistan, enabling our amerkan cousins
to
> redeploy troops from there to Iraq. The PMO’s thinking that it
was
> less costly to deploy Canadian Forces to Afghanistan than Iraq.
But
> alas no one seems to remind the Liberals of Prime Minister
Chretien’s
> then grossly incorrect assumption. Notwithstanding Jean
Chretien’s
> incompetence and stupidity, the Canadian Army was
heroic,
> professional, punched well above it’s weight, and the PPCLI
Battle
> Group, is credited with “saving Afghanistan” during the
Panjway
> campaign of 2006.
>
> What Justin Trudeau and the
Liberals don’t tell you now, is that then
> Liberal Prime Minister Jean
Chretien committed, and deployed the
> Canadian army to Canada’s longest
“war” without the advice, consent,
> support, or vote of the Canadian
Parliament.
>
> What David Amos and the rest of the ignorant,
uneducated, and babbling
> chattering classes are too addled to understand
is the deployment of
> less than 75 special operations troops, and what is
known by planners
> as a “six pac cell” of fighter aircraft is NOT the
same as a
> deployment of a Battle Group, nor a “war”
make.
>
> The Canadian Government or The Crown unlike our amerkan
cousins have
> the “constitutional authority” to commit the Canadian
nation to war.
> That has been recently clearly articulated to the
Canadian public by
> constitutional scholar Phillippe Legasse. What
Parliament can do is
> remove “confidence” in The Crown’s Government in a
“vote of
> non-confidence.” That could not happen to the Chretien
Government
> regarding deployment to Afghanistan, and it won’t happen in
this
> instance with the conservative majority in The Commons regarding
a
> limited Canadian deployment to the Middle East.
>
>
President George Bush was quite correct after 911 and the terror
> attacks
in New York; that the Taliban “occupied” and “failed state”
> Afghanistan
was the source of logistical support, command and control,
> and training
for the Al Quaeda war of terror against the world. The
> initial defeat,
and removal from control of Afghanistan was vital and
>
> P.S.
Whereas this CBC article is about your opinion of the actions of
> the
latest Minister Of Health trust that Mr Boudreau and the CBC have
> had my
files for many years and the last thing they are is ethical.
> Ask his
friends Mr Murphy and the RCMP if you don't believe me.
>
>
Subject:
> Date: Tue, 30 Jan 2007 12:02:35 -0400
> From: "Murphy,
Michael B. \(DH/MS\)" MichaelB.Murphy@gnb.ca
>
To: motomaniac_02186@yahoo.com
>
>
January 30, 2007
>
> WITHOUT PREJUDICE
>
> Mr. David
Amos
>
> Dear Mr. Amos:
>
> This will acknowledge
receipt of a copy of your e-mail of December 29,
> 2006 to Corporal Warren
McBeath of the RCMP.
>
> Because of the nature of the allegations
made in your message, I have
> taken the measure of forwarding a copy to
Assistant Commissioner Steve
> Graham of the RCMP “J” Division in
Fredericton.
>
> Sincerely,
>
> Honourable Michael B.
Murphy
> Minister of Health
>
> CM/cb
>
>
>
Warren McBeath warren.mcbeath@rcmp-grc.gc.ca
wrote:
>
> Date: Fri, 29 Dec 2006 17:34:53 -0500
> From:
"Warren McBeath" warren.mcbeath@rcmp-grc.gc.ca
>
To: kilgoursite@ca.inter.net,
MichaelB.Murphy@gnb.ca,
>
nada.sarkis@gnb.ca,
wally.stiles@gnb.ca,
dwatch@web.net,
>
motomaniac_02186@yahoo.com
>
CC: ottawa@chuckstrahl.com,
riding@chuckstrahl.com,John.Foran@gnb.ca,
>
Oda.B@parl.gc.ca,"Bev
BUSSON" bev.busson@rcmp-grc.gc.ca,
>
"Paul Dube" PAUL.DUBE@rcmp-grc.gc.ca
>
Subject: Re: Remember me Kilgour? Landslide Annie McLellan has
> forgotten
me but the crooks within the RCMP have not
>
> Dear Mr.
Amos,
>
> Thank you for your follow up e-mail to me today. I was on
days off
> over the holidays and returned to work this evening. Rest
assured I
> was not ignoring or procrastinating to respond to your
concerns.
>
> As your attachment sent today refers from Premier
Graham, our position
> is clear on your dead calf issue: Our forensic labs
do not process
> testing on animals in cases such as yours, they are
referred to the
> Atlantic Veterinary College in Charlottetown who can
provide these
> services. If you do not choose to utilize their expertise
in this
> instance, then that is your decision and nothing more can be
done.
>
> As for your other concerns regarding the US Government,
false
> imprisonment and Federal Court Dates in the US, etc... it is
clear
> that Federal authorities are aware of your concerns both in
Canada
> the US. These issues do not fall into the purvue of
Detachment
> and policing in Petitcodiac, NB.
>
> It was
indeed an interesting and informative conversation we had on
> December
23rd, and I wish you well in all of your future endeavors.
>
>
Sincerely,
>
> Warren McBeath, Cpl.
> GRC Caledonia
RCMP
> Traffic Services NCO
> Ph: (506) 387-2222
> Fax: (506)
387-4622
> E-mail warren.mcbeath@rcmp-grc.gc.ca
>
>
>
>
Alexandre Deschênes, Q.C.,
> Office of the Integrity Commissioner
>
Edgecombe House, 736 King Street
> Fredericton, N.B. CANADA E3B
5H1
> tel.: 506-457-7890
> fax: 506-444-5224
> e-mail:coi@gnb.ca
>
>
>
---------- Forwarded message ----------
> From: David Amos motomaniac333@gmail.com
>
Date: Wed, Sep 23, 2015 at 10:35 AM
> Subject: RE My complaint against the
CROWN in Federal Court Attn David
> Hansen and Peter MacKay If you
planning to submit a motion for a
> publication ban on my complaint trust
that you dudes are way past too late
> To: David.Hansen@justice.gc.ca,
peter.mackay@justice.gc.ca
>
peacock.kurt@telegraphjournal.com,
mclaughlin.heather@dailygleaner.com,
>
david.akin@sunmedia.ca,
robert.frater@justice.gc.ca,
paul.riley@ppsc-sppc.gc.ca,
>
greg@gregdelbigio.com,
joyce.dewitt-vanoosten@gov.bc.ca,
>
joan.barrett@ontario.ca,
jean-vincent.lacroix@gouv.qc.ca,
>
peter.rogers@mcinnescooper.com
Trial set for June over bank's convoluted arrangement of shell companies, loans and stock swaps
By Zach Dubinsky, Harvey Cashore, CBC NewsPosted: Nov 08, 2017 5:00 AM ET
Bank of Montreal avoided taxes for five years using a
complicated system of transactions known as "tower structures" and
"double dipping." (Doug Ives/The Canadian Press)
The Bank of Montreal ran an "abusive" tax avoidance scheme for five
years using foreign shell companies that deliberately thwarted Canada's
tax laws, the federal government alleges.
Tax Court of Canada documents, obtained by CBC News and the Toronto
Star, describe how BMO's U.S. operations routed $1.4 billion US ($1.7
billion Cdn at the time) through companies in Nevada, Nova Scotia and
Delaware. The Canada Revenue Agency says the bank inflated its losses by
$288 million Cdn in fiscal 2010 to dodge millions in tax.
"The avoidance transactions were abusive," a Department of Justice
lawyer writes in an April 2016 filing on behalf of the CRA. The BMO
scheme "circumvented" parts of the Income Tax Act "in a manner that
frustrated or defeated its object, spirit and purpose."
The money used in the arrangement came from bonds the bank sold in
Europe and the United States. BMO doesn't dispute the transactions, but
in its court filing appealing the CRA's assessment insists they were for
"bona fide purposes," that it did not abuse the law and that the losses
were legitimate and the result of currency fluctuations.
In a statement, the bank said: "This case relates to the impact of
changes in foreign exchange rates on the funding of our U.S. operations
by one of our Canadian companies. We intend to defend our position."
News of the Tax Court battle coincides with unrelated BMO dealings in the tax-haven of Bermuda being laid bare in the Paradise Papers.
While investigating references to BMO in the trove of leaked documents,
CBC News looked into Canadian court files about the bank and discovered
records about this case.
BMO's dispute with the CRA comes as dozens of countries, including
Canada, are banding together to enact measures to limit the scope of the
various cross-border tactics big companies can use to minimize their
tax bills. Such schemes, openly employed by companies from Apple to
Starbucks, see businesses legally route profits through low-tax
jurisdictions or exploit loopholes in countries' laws.
In the BMO case, the bank used what's known in accounting circles as a
"tower structure," which involves setting up special types of companies
in the U.S. and Canada that are treated differently in each country
under their respective tax codes.
(CBC)
By transferring funds through those subsidiaries, a parent company
can take advantage of so-called double-dip financing — borrowing money
and then claiming the cost of the interest as a business expense twice,
once in Canada and once in the U.S.
"It's obvious that it was put together by smart accountants and
lawyers — I assume to maximize, under the letter of the law, tax
efficiency," said Martin Kenney, a Canadian offshore lawyer based in the
British Virgin Islands.
Many types of tower structures and double-dipping are legal in Canada
and the U.S., and the CRA has generally allowed them. But in the case
of BMO's scheme, which operated from 2005 to 2010, the bank added a
twist and ended up declaring hundreds of millions of dollars in losses
based on the 20 per cent increase in the Canadian dollar against its
U.S. counterpart during that time.
CRA won't comment
Not so fast, the CRA said. It invoked a section of the Income Tax Act
called the general anti-avoidance rule that invalidates tax-minimizing
schemes that comply with the letter of the law but thwart its spirit or
purpose.
The dispute is scheduled for trial next June in Toronto.
The CRA said it wouldn't comment on the matter while it's before the court.
The Bank of Montreal's fight with the taxman centres on a convoluted
series of loans and share purchases that began more than a decade ago
and used shell companies in Nevada, Delaware and Nova Scotia, Tax Court
filings show.
"You would use Nevada and Delaware … because they're efficient,
they're cheap to set up, lawyers are used to using them," said Martin
Kenney, a Canadian offshore lawyer based in the British Virgin Islands.
Here's what happened:
In April 2005, the bank set up a Nevada limited partnership, which
itself incorporated a Nova Scotia company as a subsidiary. The Nova
Scotia company then founded its own subsidiary in Delaware.
Shortly after, BMO's Chicago branch borrowed $150 million US ($187
million Cdn at the time) from outside lenders. It used the money to fund
the Nevada partnership. The Nevada partnership took the money and
invested it in the Nova Scotia company, which, in turn, used the funds
to buy common shares in its Delaware subsidiary.
Separately, the Nevada partnership borrowed $1.25 billion US ($1.6
billion Cdn) from banks in Europe and used that money to buy yet further
shares in the Nova Scotia company. The Nova Scotia corporation used
that money, too, to buy additional common shares in its Delaware entity.
The Nova Scotia corporation quickly swapped its common stock in the
Delaware company for preferred shares that paid dividends. The Nevada
company got preferred shares in the Nova Scotia corporation.
The Delaware company then took the nearly $1.4 billion US it had
received from the Nova Scotia corporation and lent it back to BMO's U.S.
operations based in Chicago, earning interest on those loans.
The Delaware company used the income from that interest to pay
dividends on its preferred shares to the Nova Scotia company, which in
turn paid dividends on its own preferred shares to the Nevada
partnership.
When BMO unwound the tower structure in 2010, the Canadian dollar
had gone up more than 20 per cent since 2005 against the U.S. dollar.
That led the bank to claim a $322-million Cdn capital loss on the Nevada
partnership's common shares in the Nova Scotia company. The CRA doesn't
object to some of that loss, according to the court documents, but
deems $288 million to be inflated.
Normally, such a loss would be offset by any dividends the Nevada
partnership received on its common shares in the Nova Scotia company.
But because the dividends came via preferred shares and not common
shares, the bank didn't factor them in to reduce its claimed loss.
The CRA alleges that BMO had no bona fide reason to pay dividends
through the preferred shares as opposed to the common shares, and that
the "primary purpose and result" of that decision "was the
circumvention" of the relevant section of the Income Tax Act in a way
that was an "abuse, having regard to the act read as a whole."
BMO's offshore dealings detailed in Paradise Papers leak
Bank execs running a subsidiary in Bermuda fretted over possible visits from taxman, files show
By Zach Dubinsky, Harvey Cashore, CBC NewsPosted: Nov 08, 2017 5:00 AM ET
The Paradise Papers leak provides a look at the offshore
manoeuvrings of the Bank of Montreal, including what senior executives
fretted about behind closed doors as they ran a subsidiary based in
Bermuda. (Chris Helgren/Reuters)
It was a blustery, grey day in Bermuda, and a clutch of Bank of
Montreal executives who had flown in were huddled in a board room.
Top of the agenda for the March 2013 meeting: how to lessen the
burden of flying six executives to the palm-fringed island a couple
times a year — the bare bones required for tax purposes to officially
keep a subsidiary there with no staff, no desks, no phones and no
premises.
Two years earlier, BMO had acquired Lloyd George
Management, an investment firm focused on Asia. LGM, as it's known, had
most of its staff at two subsidiaries in Hong Kong and London. But its
parent company was incorporated in zero-tax Bermuda — despite having
nothing more there than a mailbox at a law firm specializing in offshore
financial services.
To keep up the legal appearance of the company's Bermuda
residency, a majority of LGM's board of directors — made up mostly of
BMO senior managers — had to meet in person on the island at least twice
a year. If not, there would be a risk the company could be deemed to
reside elsewhere, possibly in Canada, where it may have to pay tax.
And there was the catch: It was proving tough to get enough
people to jet down to Bermuda for the board meetings, according to the
BMO executive chairing the gathering.
"We were having trouble getting six people to attend the
meeting every time in Bermuda," said the executive, Barry Cooper,
according to a transcript of the meeting.
The solution? They cut the number of people on the board from
11 to seven. Now only four directors would have to attend in person in
Bermuda in order to "have fulfilled the tax guidelines," Cooper said.
Thousands of leaked files
This unprecedented glimpse behind the scenes as a big Canadian
bank struggled with running one of its offshore subsidiaries comes from
the Paradise Papers, the huge leak of tax-haven financial records that
was made public Sunday. The leak was obtained by German newspaper
Suddeutsche Zeitung and shared exclusively in Canada with
CBC/Radio-Canada and the Toronto Star via the International Consortium
of Investigative Journalists.
It contains thousands of documents relating to all five of
Canada's big banks, most of them to do with the mundane, daily details
of operating a globe-spanning financial conglomerate. Much of the
material comes from Appleby, a law firm that offers offshore legal and
administration services in eight tax havens around the world.
The Paradise Papers leak includes millions of
records from offshore law firm Appleby and the corporate registries of
19 tax havens. (AFP/Getty Images)
Among the leaked files is a transcript of discussions during
that 2013 meeting. The board members in attendance later turned their
attention to concerns about potentially being hit with a big tax bill.
LGM's operations in Hong Kong had been routing as much profit as
possible to the offshore parent company in Bermuda.
"We booked as much of our income as we could here," said LGM's founder, according to the leaked transcript.
But times had changed. The world's biggest economies, including Canada, had united
to devise measures limiting the scope of various cross-border tactics
big companies can use to minimize their tax. Arrangements openly
employed by companies like Apple, Starbucks and banks, see businesses
legally route profits through low-tax jurisdictions or exploit loopholes
in foreign tax laws.
LGM had recently scaled back its profit shifting, and board
members were worried the Hong Kong tax authorities might notice and go
back and scrutinize previous fiscal years — possibly demanding more tax
be paid.
'Hopefully, we just let these things run off and times run out.'
- A BMO executive
"How long are we possibly liable?" asked one of them, whose identity is not clear from the transcript.
Another board member mentioned that Hong Kong has a statute of
limitations to reassess old tax returns. "I think it's six years," the
board member said.
Some discussion ensued.
"Hopefully, we just let these things run off and times run out," a BMO executive said.
"No news is good news," another unidentified board member chimed in.
They resolved to take a wait-and-see approach.
'No active clients'
In a statement to CBC and the Toronto Star, BMO acknowledged
that its LGM Bermuda operation has "no active clients." The bank did not
directly address questions about why, then, it keeps the island shell
corporation going or what tax advantages it derives.
"We have robust governance in place for our subsidiaries,
including strategic oversight of the business by their respective boards
as well as oversight to ensure compliance with tax and all other laws,"
the bank said.
BMO also wouldn't say why it felt the need to change LGM's
accounting to book more of its profits in Hong Kong, and in particular,
whether the previous practice was flawed. All the bank would say is that
it "reviewed LGM's arrangements" before and after acquiring it "to
ensure they conformed to BMO's policies."
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ReplyDeleteI'm Dr Ogudugu, a real and genuine spell caster/Spiritual healer with years of experience in spell casting and an expert in all spells, i specialize exclusively in LOVE SPELL/GET REUNITE WITH EX LOVER, MONEY SPELL, POWERFUL MAGIC RING, ANY COURT CASES, FRUIT OF THE WOMB, HIV CURE, CURE FOR CANCER, HERPES, DIABETE, HERPERTITIS B, PARKINSON’S HERBAL CURE, BECOMING A MERMAID, BECOMING A VAMPIRE, SAVE CHILD BIRTH. They are all %100 Guaranteed QUICK Results, it most work. If you have any problem and you need a real and genuine spell caster to solve your problems, contact me now through my personal Email Address with problem case...Note-you can also Text/Call on WhatsApp.
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WhatsApp No: +27663492930