Cross-border nurses say they paid their taxes — but CRA took their money and froze their accounts
'I couldn't pay my bills,' says one nurse who works in Michigan
After calling her bank, Christensen found out that Canada Revenue Agency (CRA) had placed a hold on her account at the end of November and taken money out.
"They took almost $1,600 away from me," she said.
"Currently, my bank account is -$250."
Some
Windsor-based workers who work in Detroit say the Canada Revenue Agency
have taken their money and frozen their accounts but the workers say
they have paid their taxes. (Carlos Osorio/The Associated Press)
Christensen is a registered nurse who lives in Windsor, Ont., and works for a children's hospital in Detroit. Because of this, she has to file taxes in both Canada and the U.S.
According to Christensen, CRA said she owed $32,713.62 in back taxes, which Christensen does not believe she owes. She said the agency has placed a lien on her account for about the same amount, though Christensen says she submitted proof that she paid her taxes.
For a single mom like Christensen, she said the lack of funds has made things stressful.
"My daughter has occasionally asked me, 'Did you get your money back?,'" she said. "I don't know if she's as stressed as I am."
They took almost $1,600 away from me. Currently, my bank account is -$250.
- Lora Christensen, cross-border worker
In addition to travelling to a different country for work, cross-border workers also have to navigate two different systems of taxation, and Christensen is not the only cross-border worker facing frustrations with the CRA.
Fellow nurse Isabelle Tardif posted a similar story to Christensen's, with many others commenting, in a private Facebook group called "Proud to be a Canadian Nurse in Michigan."
CRA claims that Tardif owes $59,000 in back taxes, she told CBC News. She says CRA took $12,000 US, which was all of her savings. In May, her accounts were frozen as well.
Tardif says she also provided CRA proof of payment of her taxes. She submitted her U.S. files from 2018 to 2020, but said the Internal Revenue Service (IRS) still has not processed her taxes for 2021.
Gail Chene, manager at Ferrara Income Tax in Windsor, says that the average tax return takes six to eight months for the IRS to process. She also said that this could be what is contributing to the issues Christensen and Tardif are facing.
Although Tardif has since regained access to her bank account, she has filed an objection.
"Now, I'm on a seven-month waiting list with the chief of appeals to try and get my money back," she said.
Isabelle
Tardif is a nurse at Henry Ford Hospital in Detroit. She had to secure a
loan from a family member to help pay her mortgage and is paying with
everything using her credit card. (TJ Dhir/CBC)
Tardif was able to secure a loan from a family member to help pay her mortgage. The lack of funds in her bank account meant that she has had to pay for everything with her credit card.
"I couldn't pay my bills," she said. "They didn't even leave me $10.
"They took everything."
Tax system for cross-border workers
Canadians who work in the U.S. are required to pay taxes in the U.S. before they pay taxes in Canada, explained Ian Murphy, tax partner with MCO Partners. They are required to pay separate federal, state, municipal, social security and medical taxes in the U.S.
"All [of that] combined together, converted into Canadian dollars, they get to claim that as a foreign tax credit against their Canadian taxes," said Murphy. "In Canada, taxes are based on your worldwide income if you're a Canadian resident. In the U.S., in this situation, you would only be taxed on your earned income."
The process relies on proof of taxes being filed in the U.S., which Tardif and Christensen say they provided to CRA.
Ian
Murphy is a tax partner with MCO Partners in Windsor. He says the
Canada Revenue Agency is under-staffed, under-trained and "broke,"
creating a massive backlog of cases. (TJ Dhir/CBC)
CBC News has reached out to CRA for comment but the agency was unable to respond before deadline. This article will be updated with CRA's response.
Murphy said there are massive backlogs at CRA because the agency is under-staffed, under-trained and "broke."
"They handed out a lot of money during COVID," he said. "I think they're going to exhaust a lot of their own agents. I understand they need to up the measures for collecting taxes, but I don't know if this is the place where they're going to get much bang for their buck."
Tardif said that she and other workers have reached out to local MPs about their struggles. CBC News has contacted the offices of Irek Kusmierczyk and Brian Masse for comment. Masse's office said the MP has written to the federal Minister of National Revenue.
"I believe you need to put a stop immediately to the freezing of Canadian's bank accounts for debts which are not legitimate," Masse's letter reads. "Your current process not only spends time and resources on Canadian law-abiding taxpayers, but it is also particularly harsh and cruel on people trying to follow the law."
Murphy said his advice is to sort things out with the CRA agent assigned to the case and that they are usually sympathetic.
"When I talk to collections agents on the phone, I say to them, 'We uploaded everything months ago. Your own system is behind,'" he said. "If you tell them it's a foreign tax credit, most of them will say, 'I'll call you back in three to six months.'
"And they drop it immediately."
ABOUT THE AUTHOR
Comments
David Amos
I know I can help these nurses but I doubt they would believe me
Clive Eastman
Reply to David Amos
How so David.
David Amos
Reply to Clive Eastman
Ask Mr Murphy and his partners
Automatic reply: Re The CRA in the news again Deja Vu anyone???
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Re The CRA in the news again Deja Vu anyone???
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| To: dmilot@milotlaw.ca, contactus@taxationlawyers.ca, acampbell@legacylawyers.ca, jdp@tdslaw.com, "Nathalie.Drouin" <Nathalie.Drouin@justice.gc.ca>, Diane.Lebouthillier@parl.gc.ca, "erin.otoole" <erin.otoole@parl.gc.ca>, pm <pm@pm.gc.ca>, premier <premier@ontario.ca>, Newsroom <Newsroom@globeandmail.com>, "jagmeet.singh" <jagmeet.singh@parl.gc.ca>, "Bill.Blair" <Bill.Blair@parl.gc.ca>, "Brenda.Lucki" <Brenda.Lucki@rcmp-grc.gc.ca>, mcu <mcu@justice.gc.ca>, nathalie.sturgeon@globalnews.ca, "Jason.Proctor" <Jason.Proctor@cbc.ca>, "John.Williamson" <John.Williamson@parl.gc.ca>, "Ross.Wetmore" <Ross.Wetmore@gnb.ca>, "blaine.higgs" <blaine.higgs@gnb.ca>, "rob.moore" <rob.moore@parl.gc.ca>, "Robert. Jones" <Robert.Jones@cbc.ca>, "steve.murphy" <steve.murphy@ctv.ca>, "Melanie.Joly" <Melanie.Joly@parl.gc.ca>, "Mark.Blakely" <Mark.Blakely@rcmp-grc.gc.ca>, "martin.gaudet" <martin.gaudet@fredericton.ca>, "Mitton, Megan (LEG)" <megan.mitton@gnb.ca>, "michael.macdonald" <michael.macdonald@thecanadianpress.com>, sheilagunnreid <sheilagunnreid@gmail.com>, "silas.brown" <silas.brown@globalnews.ca>, christian.lorenz@international.gc.ca | |||||||||||
| Cc: motomaniac333 <motomaniac333@gmail.com>, tj.dhir@cbc.ca | |||||||||||
---------- Forwarded message ---------- From: David Amos <david.raymond.amos333@gmail. Date: Tue, 13 Dec 2022 15:43:55 -0400 Subject: Fwd: Re The CRA in the news again Deja Vu anyone??? To: aammoscato@taxmco.com ---------- Forwarded message ---------- From: David Amos <david.raymond.amos333@gmail. Date: Tue, 13 Dec 2022 15:34:59 -0400 Subject: Fwd: Re The CRA in the news again Deja Vu anyone??? To: imurphy@taxmco.com Cc: motomaniac333 <motomaniac333@gmail.com> https://www.cbc.ca/news/ Ian Murphy is a tax partner with MCO Partners in Windsor. He says the Canada Revenue Agency is under-staffed, under-trained and "broke," creating a massive backlog of cases. (TJ Dhir/CBC) Comments David Amos I know I can help these nurses but I doubt they would believe me [Ian-Murphy] IAN MURPHY CPA, CA 519-253-6077 ext. 226 ---------- Forwarded message ---------- From: David Amos <david.raymond.amos333@gmail. Date: Fri, 7 Oct 2022 15:13:53 -0300 Subject: Re The CRA in the news again Deja Vu anyone??? To: dmilot@milotlaw.ca, contactus@taxationlawyers.ca, acampbell@legacylawyers.ca, jdp@tdslaw.com, "Nathalie.Drouin" <Nathalie.Drouin@justice.gc.ca "erin.otoole" <erin.otoole@parl.gc.ca>, pm <pm@pm.gc.ca>, premier <premier@ontario.ca>, Newsroom <Newsroom@globeandmail.com>, "jagmeet.singh" <jagmeet.singh@parl.gc.ca>, "Bill.Blair" <Bill.Blair@parl.gc.ca>, "Brenda.Lucki" <Brenda.Lucki@rcmp-grc.gc.ca>, mcu <mcu@justice.gc.ca>, nathalie.sturgeon@globalnews. "Jason.Proctor" <Jason.Proctor@cbc.ca>, "John.Williamson" <John.Williamson@parl.gc.ca>, "Ross.Wetmore" <Ross.Wetmore@gnb.ca>, "blaine.higgs" <blaine.higgs@gnb.ca>, "rob.moore" <rob.moore@parl.gc.ca>, "Robert. Jones" <Robert.Jones@cbc.ca>, "steve.murphy" <steve.murphy@ctv.ca>, "Melanie.Joly" <Melanie.Joly@parl.gc.ca>, "Mark.Blakely" <Mark.Blakely@rcmp-grc.gc.ca>, "martin.gaudet" <martin.gaudet@fredericton.ca> <megan.mitton@gnb.ca>, "michael.macdonald" <michael.macdonald@ Cc: motomaniac333 <motomaniac333@gmail.com>, sheilagunnreid <sheilagunnreid@gmail.com>, "silas.brown" <silas.brown@globalnews.ca>, christian.lorenz@ ---------- Forwarded message ---------- From: "Lorenz, Christian" <Christian.Lorenz@cbsa-asfc. Date: Fri, 7 Oct 2022 17:32:23 +0000 Subject: Automatic reply: Attn Jeff Pniowsky I was readig about you in CBC today perhaps we should talk ASAP? To: David Amos <david.raymond.amos333@gmail. This email is not routinely monitored. I am in my new role as Regional Director, Europe, Africa and Middle East, and can be reached at: christian.lorenz@ effective 15 August 2022. Thank you. ** Cette addresse courriel n'est pas surveillée régulièrement. Je suis dans mon nouveau rôle comme Directeur Régional, Europe, Afrique et Moyen-Orient, et peux être rejoint au: christian.lorenz@ Merci. ---------- Forwarded message ---------- From: David Amos <david.raymond.amos333@gmail. Date: Fri, 12 Mar 2021 15:00:03 -0400 Subject: Re The CRA in the news again Deja Vu anyone??? To: dmilot@milotlaw.ca, contactus@taxationlawyers.ca, acampbell@legacylawyers.ca, jdp@tdslaw.com, "Nathalie.Drouin" <Nathalie.Drouin@justice.gc.ca "erin.otoole" <erin.otoole@parl.gc.ca>, pm <pm@pm.gc.ca>, premier <premier@ontario.ca>, Newsroom <Newsroom@globeandmail.com>, "jagmeet.singh" <jagmeet.singh@parl.gc.ca>, "Bill.Blair" <Bill.Blair@parl.gc.ca>, "Brenda.Lucki" <Brenda.Lucki@rcmp-grc.gc.ca>, mcu <mcu@justice.gc.ca> Cc: motomaniac333 <motomaniac333@gmail.com>, Nathalie Sturgeon <sturgeon.nathalie@ <Jason.Proctor@cbc.ca>, "John.Williamson" <John.Williamson@parl.gc.ca>, "Ross.Wetmore" <Ross.Wetmore@gnb.ca>, "blaine.higgs" <blaine.higgs@gnb.ca>, "rob.moore" <rob.moore@parl.gc.ca>, "Robert. Jones" <Robert.Jones@cbc.ca>, "steve.murphy" <steve.murphy@ctv.ca> https://davidraymondamos3. Sunday, 7 March 2021 RCMP threaten a BC church with Canada Revenue Agency investigation??? NOW THATS TOO TOO FUNNY INDEED https://www.cbc.ca/news/ Canada Revenue Agency accused of blaming victims as 'gross negligence' cases drag on B.C. retiree who won appeal of $139K penalty claimed she didn't know what was filed on her behalf Jason Proctor · CBC News · Posted: Mar 11, 2021 5:45 PM PT About the Author Jason Proctor @proctor_jason Jason Proctor is a reporter in British Columbia for CBC News and has covered the B.C. courts and mental health issues in the justice system extensively. https://www.tdslaw.com/person/ Jeff Pniowsky Jeff focuses his practice in the areas of tax litigation and dispute resolution in the tax audit and appeals process, tax advisory services, and complex commercial litigation. (204) 934-0586 jdp@tdslaw.com https://www.canlii.org/en/ca/ Signed at Ottawa, Canada, this 2nd day of March 2021. “Sylvain Ouimet” Ouimet J. CITATION: 2021 TCC 14 COURT FILE NO.: 2016-1686(IT)G STYLE OF CAUSE: MARGO DIANNE BOWKER AND HER MAJESTY THE QUEEN PLACE OF HEARING: Vancouver, British Columbia DATE OF HEARING: February 10, 11, 12 and 13, 2020 REASONS FOR JUDGMENT BY: The Honourable Justice Sylvain Ouimet DATE OF JUDGMENT: ---------- Forwarded message ---------- From: David Amos <david.raymond.amos333@gmail. Date: Fri, 7 Oct 2022 14:47:27 -0300 Subject: Fwd: Attn Jeff Pniowsky I was readig about you in CBC today perhaps we should talk ASAP? To: hmartinez@tdslaw.com, cdacosta@tdslaw.com Cc: motomaniac333 <motomaniac333@gmail.com> ---------- Forwarded message ---------- From: Danielle Delorme <ddelorme@tdslaw.com> Date: Fri, 7 Oct 2022 17:40:00 +0000 Subject: Automatic reply: Réponse automatique : Attn Jeff Pniowsky I was readig about you in CBC today perhaps we should talk ASAP? To: David Amos <david.raymond.amos333@gmail. I will be out of the office Friday, September 30th and returning Tuesday, October 11th. I will not be checking emails during this time. If you requrie assistance before October 11th, please contact either: Colleen Da Costa 204-934-2340 cdacosta@tdslaw.com Heather Martinez 204-934-2379 hmartinez@tdslaw.com Thank you, Danielle Delorme Click the following link to unsubscribe or subscribe to TDS e-communications: Unsubscribe at https://tdslaw.us3.list- Subscribe at https://www.tdslaw.com/ ---------- Forwarded message ---------- From: David Amos <david.raymond.amos333@gmail. Date: Fri, 7 Oct 2022 14:32:11 -0300 Subject: Attn Jeff Pniowsky I was readig about you in CBC today perhaps we should talk ASAP? To: jdp@tdslaw.com, mcu <mcu@justice.gc.ca> Cc: motomaniac333 <motomaniac333@gmail.com>, "Jason.Proctor" <Jason.Proctor@cbc.ca>, "blaine.higgs" <blaine.higgs@gnb.ca>, Diane.Lebouthillier@cra-arc. Andrew.Baumberg@cas-satj.gc.ca <Ellen.Desmond@crtc.gc.ca>, Christian.Lorenz@cbsa-asfc.gc. Allison.St-Jean@tc.gc.ca, media@tc.gc.ca, hc.media.sc@canada.ca, mary-liz.power@canada.ca, media@cbsa-asfc.gc.ca, Chris.Lorenz@cbsa-asfc.gc.ca, "christopher.rupar" <christopher.rupar@justice.gc. https://www.cbc.ca/news/ New Brunswick·CBC Investigates How to keep secrets from the public: Don't write anything down https://www.cbc.ca/news/ Judge slams CRA and Justice Department for 'egregious' conduct in epic Tax Court battle Decision likely to affect dozens of Canadians appealing gross negligence penalties from tax agency Jason Proctor · CBC News · Posted: Oct 07, 2022 4:00 AM PT | A tax Court judge has slammed the Canada Revenue Agency for failing to comply with pre-trial court rules and orders. (Chris Wattie/Reuters) A Tax Court judge has slammed the Canada Revenue Agency and the Justice Department for "egregious" conduct that threatened to deny three taxpayers the right to a fair trial in an epic battle over millions of dollars worth of tax penalties. In a scathing decision that could have widespread implications, Judge Patrick Boyle found the CRA committed an "intentional and deliberate" pattern of ignoring court rules to "frustrate" the right that all Canadians have to get a full picture of an opponent's case before heading to court. The three taxpayers — a Manitoba psychiatrist, an Ontario nurse and a B.C. Air Canada pilot — were appealing three million dollars' worth of gross negligence penalties levelled against them, for rejected returns filed through a pair of disgraced tax consultancy firms. But after years of pre-trial delays resulting from the CRA's repeated failure to comply with his orders, Boyle took the extraordinary measure of allowing the appeals without having a trial on the merits of the case this week, to "protect the integrity of the judicial process." Canada Revenue Agency accused of blaming victims as 'gross negligence' cases drag on "I find the [CRA's] egregious approach to pre-trial discovery in these appeals to prejudice all three appellants who have been denied," Boyle wrote in his ruling. "These abuses of the discovery process ... have caused considerable delay and expense to three Appellants in respect of their appeals. They have also led to an inefficient use of public resources financed by all Canadians." 'With great power comes great responsibility' Boyle's decision is the latest chapter in a saga that has seen hundreds of Canadians slapped with gross negligence penalties after filing returns through DeMara Consulting and Fiscal Arbitrators. The principals of both companies were jailed for tax fraud for promoting schemes Boyle says "resemble in many respects the de-taxation practices of sovereign citizens, though with less of the non-fiscal cultish aspects." Hundreds of Canadians filed appeals in Tax Court after the CRA levelled gross negligence penalties against them in association with returns filed through a pair of disgraced tax consultancies. (Minichka / Shutterstock) According to court records, B.C.-based DeMara's scheme was called "the remedy" and essentially involved claiming personal expenditures and debts as expenses and capital losses for a non-existent business. Canada's Income Tax Act gives CRA the ability to levy penalties against Canadians who make false statements and omissions on their tax returns, either knowingly or under circumstances that amount to gross negligence. The penalties in the DeMara and Fiscal Arbitrators case have reached into the millions, leading to a huge backlog of appeals that have been making their way through tax court since 2013. Tax agency obtains 'jeopardy order' for debt from Downton Abbey-loving billionaire Jeff Pniowsky, the Winnipeg-based lawyer who represented all three plaintiffs, said fighting a decade-long court battle with the threat of financial ruin hanging over their heads has cost his clients "years of happiness." "This was fundamentally a case about justice. Justice for the taxpayers who had to endure years of gamesmanship and chicanery by one of Canada's most powerful institutions: the CRA," Pniowsky told the CBC. Pniowsky, who has four children, said Boyle's ruling reminded him of a line from one of his family's favourite superhero movies: Spiderman. "With great power comes great responsibility," he said. "It's clear from this case that the CRA and the Justice Department have lost sight of that common-sense principle." 'Unprepared, unco-operative or untruthful' Boyle's detailed 53-page ruling goes through the history of the case, and the circumstances that led to each of the orders he found the CRA later ignored. The fight centred on pre-trial discovery, and the rights of the taxpayers to examine a CRA representative or "nominee" who was "knowledgeable" about their case. The CRA has the ability to levy gross negligence penalties against taxpayers who lie on their income tax forms. The penalties have been devastating for some. (Graeme Roy/The Canadian Press) The first person the agency put forward was "unaware of any criminal investigation and had not informed himself" about any involvement of the CRA's criminal investigators in the case. The second nominee was a lead criminal investigator who "did not even inform himself ... whether any investigation was undertaken of any of these three appellants." At one point, Boyle called the investigator "thoroughly unprepared, unco-operative or untruthful." The judge said the CRA and its lawyers twisted the words of an order that boiled down to a demand for the agency to hand over any documents relating to any investigations that touched on the three appellants. "I variously described this as 'outrageously misleading and inappropriate,' 'this might be contemptuous,' ... 'deeply, deeply disturbed,' 'highly inappropriate' and 'I don't think you were reasonably mistaken,'" Boyle wrote. It is an ex-reference: B.C. judge removes 'dead parrot' joke from class-action ruling The judge also zeroed in on the CRA's failure to tell the defence that the second page of a three-page "Investigation Abort Report" against one of the plaintiffs had gone missing. The report was handed over in the middle of hundreds of documents. The missing page explained why a criminal investigation was dropped. The CRA claimed it had no "specific obligation" to point out missing pages — a position Boyle found "shocking." "Courts do not consider discovery to be a game, and it is particularly disappointing when the Crown is the offending party," the judge said. He said the omission gave credence to the idea the CRA "is hiding something from them, from the Court and from Canadians about how these investigations have been conducted. 'Stop, or I'll yell stop again!' The judge pointed out that the CRA is "represented by the Department of Justice which is essentially Canada's largest national law firm and employs a large number of tax litigation lawyers who are wholly familiar" with the court's rules. Boyle said making yet another order for compliance would be pointless. The judge compared his battle to get the CRA to comply with his orders to a skit by Monty Python, whose troupe members are seen here from left to right: John Cleese, Terry Gilliam, Terry Jones, Graham Chapman, Michael Palin and Eric Idle. (PBS/Python (Monty) Pictures Ltd./The Associated Press) He was reminded of a skit by legendary English comedy troupe Monty Python. "To make such an order would conjure up memories of the Pythonesque skit of the British bobby of another era yelling at a scofflaw: 'Stop! Stop!—Stop, or I'll yell 'stop' again!'" the judge wrote. The three appeals were supposed to be the lead plaintiffs for a much larger group of appeals. The judge said those people will have to speak with their lawyers to determine how the ruling applies to them. Pniowsky says he believes the decision is the first of its kind against the CRA. He predicted fallout both in other DeMara and Fiscal Arbitrators cases and in the wider world of tax litigation. "Intoxicated with a sense of moral righteousness, the government apparently determined or acted like these Canadians were not worthy of basic procedural rights, thereby committing the same wrongs they accused the taxpayers of: gross neglect, wilful blindness and at times deceptive conduct," he said. ABOUT THE AUTHOR Jason Proctor @proctor_jason Jason Proctor is a reporter in British Columbia for CBC News and has covered the B.C. courts and the justice system extensively. CBC's Journalistic Standards and Practices https://www.tdslaw.com/ Jeff Pniowsky Jeff focuses his practice in the areas of tax litigation and dispute resolution in the tax audit and appeals process, tax advisory services, and complex commercial litigation. (204) 934-2586 jdp@tdslaw.com Winnipeg (204) 934-0586 Profile Jeff is a partner with TDS who focuses his practice in the areas of tax litigation and dispute resolution in the tax audit and appeals process, tax advisory services, as well as complex commercial litigation. Formerly a senior Tax Litigator with the Federal Department of Justice acting on behalf of the Canada Revenue Agency (CRA) for almost 10 years, Jeff now serves local and national clients with a wealth of experience in litigating at all levels of both the Provincial and Federal courts, including the Supreme Court of Canada. His work has included challenges to complex tax avoidance techniques involving large corporate transactions, international taxation and interpretation of tax treaties. Jeff has advised the Aggressive Tax Planning Division of CRA involving some of the most significant tax matters in the Prairie region. He also sat on the National Tax Avoidance committee for Justice Canada. In addition, Jeff has extensive experience dealing with tax enforcement and other regulatory compliance issues including disclosure requirements and was a member of national Documentary Requirements Committee. He is also considered an authority on solicitor and client privilege issues relating to documentary disclosure, having litigated several matters in this area as well as being called upon to act as an adjudicator in a privilege determination. ---------- Forwarded message ---------- From: David Amos <david.raymond.amos333@gmail. Date: Sun, 7 Feb 2021 23:52:35 -0400 Subject: Diane.Lebouthillier and her old buddy John Ossowski should remember my email and a couple of their own documents EH Madame Desmond and Christian Lorenz ? To: "Diane.Lebouthillier" <Diane.Lebouthillier@cra-arc. John.Ossowski@cbsa-asfc.gc.ca, megan.maloney@crtc.gc.ca, bell.regulatory@bell.ca, martine.turcotte@bell.ca, Newsroom <Newsroom@globeandmail.com>, Nathalie Sturgeon <sturgeon.nathalie@ <Nathalie.Drouin@justice.gc.ca <traversy.n@gmail.com>, jswaisland@landingslaw.com, Andrew.LeFrank@cbsa-asfc.gc.ca Cc: motomaniac333 <motomaniac333@gmail.com>, "Ellen.Desmond" <Ellen.Desmond@crtc.gc.ca>, Christian.Lorenz@cbsa-asfc.gc. Allison.St-Jean@tc.gc.ca, media@tc.gc.ca, hc.media.sc@canada.ca, mary-liz.power@canada.ca, media@cbsa-asfc.gc.ca, Chris.Lorenz@cbsa-asfc.gc.ca, "christopher.rupar" <christopher.rupar@justice.gc. ----- Original Message ----- From: martine.turcotte@bell.ca To: motomaniac_02186@hotmail.com Cc: bcecomms@bce.ca ; W-Five@ctv.ca Sent: Thursday, August 19, 2004 9:28 AM Subject: RE: I am curious Mr. Amos, I confirm that I have received your documentation. There is no need to send us a hard copy. As you have said yourself, the documentation is very voluminous and after 3 days, we are still in the process of printing it. I have asked one of my lawyers to review it in my absence and report back to me upon my return in the office. We will then provide you with a reply. Martine Turcotte Chief Legal Officer / Chef principal du service juridique BCE Inc. / Bell Canada 1000 de La Gauchetière ouest, bureau 3700 Montréal (Qc) H3B 4Y7 Tel: (514) 870-4637 Fax: (514) 870-4877 email: martine.turcotte@bell.ca Executive Assistant / Assistante à la haute direction: Diane Valade Tel: (514) 870-4638 email: diane.valade@bell.ca A copy of this letter and all related correspondence will be added to the public record of the proceeding. If you have any questions or concerns, please feel free to contact me at (613) 697-4027 or megan.maloney@crtc.gc.ca. In the meantime, the Commission is currently continuing its review of this costs application. Yours Sincerely, originally signed by Megan Maloney Legal Counsel PIAC Welcomes New Board Members Adds Expertise in Telecommunications, Broadcasting and Class Actions OTTAWA – The Public Interest Advocacy Centre (PIAC), today announced the recent election of four new directors to its Board, all experts in either telecommunications, broadcasting or class actions: Konrad von Finckenstein is a lawyer and consultant based in Ottawa. He was previously Chair of the Canadian Radio-television and Telecommunications Commission (CRTC), an Honourable Justice of the Federal Court of Canada and the Commissioner of Competition at the Competition Bureau of Canada. In addition, he has held senior posts in the Government of Canada in positions related to international trade, telecommunications, competition and electronic commerce. Mr. von Finckenstein has been elected as PIAC’s Chair of the Board. Suzanne Lamarre is a lawyer and engineer with the firm of Therrien, Couture and is a former Commissioner of the CRTC. Maitre Lamarre works in the areas of telecommunications, radiocommunications and broadcasting law as a strategic advisor on regulatory and governmental matters at both the national and international level. Monica Auer is a lawyer and the Executive Director of Canada’s Forum for Research & Policy in Communications (FRPC), a non-partisan organization focused on Canada’s communications system. She previously worked at the CRTC and the Canadian Broadcasting Corporation (CBC). Ms. Auer has been elected as PIAC’s Vice-Chair. Jonathan Schachter is a Toronto based lawyer with Sotos LLP, with his practice areas including class actions, consumer protection litigation, competition and price fixing, privacy litigation, professional liability litigation, and trademarks and intellectual property litigation and arbitration. “PIAC’s extensive work on behalf of consumers before the CRTC requires the utmost guidance and insight,” said John Lawford, Executive Director and General Counsel of PIAC. “We are therefore thrilled to add to our Board persons with unparalleled experience to guide our communications advocacy, as well as an expert in consumer class actions as this sector becomes more litigious,” he added. PIAC is a federally incorporated not-for-profit and registered charity that advocates for consumer interests, and in particular vulnerable consumer interests, in the provision of important public services. PIAC is known for its representation of consumer, low-income and seniors groups before the CRTC, arguing for better services, more choice and consumer protection for customers of Internet, wireless, telephone and broadcasting services. For more information, please contact: John Lawford Executive Director and General Counsel Public Interest Advocacy Centre (PIAC) (613) 562-4002 ×25 > 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??? > > ---------- Forwarded message ---------- > From: Michael Cohen <mcohen@trumporg.com> > 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 <motomaniac333@gmail.com> > > 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. > > > > > ---------- Forwarded 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 > >
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A safe forum away from all the negative press against our choice to practice in Michigan.
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Group created on April 1, 2020
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