CRA proactively shares interesting information with foreign tax authorities and Revenu Québec, and will increase use of s. 231.4 inquiries

Comments of Sue Murray, the Director General of the High Net-Worth Compliance Directorate, included:

• CRA is contemplating more frequent use of s. 231.4 to delegate the power to make inquiries, and may use it in some of the more egregious cases of offshore non-compliance if it is unable to obtain information and cooperation in other ways.
• There have been increased exchanges of information with Revenu Québec, and with whom there is a high degree of cooperation.
• CRA’s position is that, for 2018 and subsequent filing years, any failure to file a CbC report as required under s. 233.8(3) will be presumed gross negligence, absent special circumstances. Things are still in transition, and CRA would be lenient where there is ambiguity or other problems, but it expects that that would be rare.
• Where CRA, in undertaking compliance activities, comes across information that will be of interest to a foreign tax administration, it will proactively take that information and provide it to the other country. CRA expects reciprocity in this regard, and receives it.

Neal Armstrong. 14 May 2019 IFA Conference - Sue Murray on Information Exchanges.