Source URL

Disclaimer

We do not guarantee the accuracy of this copy of the CRA website.

An informant must be eligible for the Offshore Tax Informant Program (OTIP). See Eligibility for the Offshore Tax Informant Program for more details.
The information provided by the informant must show that:
- the non-compliance is international; and
- the potential federal tax, excluding interest and penalties, is greater than $100,000.
An OTIP analyst will consider the information provided by the informant, evaluate the merits of the case and make a recommendation about inclusion in the program. If a case is recommended for inclusion in the program, it is referred to an Oversight Committee of senior management representatives for approval to enter into a contract.
Once approved, the informant and the Canada Revenue Agency (CRA) will enter into a contract.
A payment can be denied and a contract can be terminated in certain situations, including where:
- the CRA already received the information from another source;
- an audit or criminal investigation is conducted but leads to an assessment of federal tax relating to international tax non-compliance that is less than $100,000;
- the taxpayer is successful in an administrative or judicial appeal resulting in an assessment of federal tax relating to international tax non-compliance that is less than $100,000; or
- less than $100,000 is collected because the taxpayer has no known assets that the CRA can use to settle the outstanding tax liability.

The CRA works to conclude the process as efficiently as possible. However, it may take several years from the date of entering into a contract with the CRA until the additional federal tax is assessed, the taxpayer's appeal rights have expired, and the amount owing is collected.

For a payment to be made under the program, the information must lead to compliance or enforcement action, result in the assessment and collection of more than $100,000 of additional federal tax (excluding penalties and interest), and all objection and appeal rights associated with the assessments must have expired. The CRA will not make any "upfront" payments.
The OTIP will determine whether a payment will be made under the contract and what the amount of the payment will be.
If the information provided contributes to the collection of federal tax owing, the award amount will be between 5% and 15% of the federal tax collected that is related to international tax non-compliance (not including interest and penalties). For information about the criteria that will be considered in determining the award percentage, go to Payment criteria.
Provided all the payment conditions are met, once $100,000 of federal tax has been collected, the CRA will initiate the payment process. Partial payments may be made as additional funds relating to the informant's submission are collected.

The contract provides a dispute resolution process for informants. An informant's grievance will be reviewed by an internal review panel comprised of senior management representatives.

Report a problem or mistake on this page