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ARTICLE · 11 SEPTEMBER 2011

CRA Target High Net Worth Individuals

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Tax administration is going global and international cooperation is increasing as revenue authorities develop strategies to counter abusive tax planning.

CanadaTax
Hugo Patenaude
Hugo Patenaude
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Tax administration is going global and international cooperation is increasing as revenue authorities develop strategies to counter abusive tax planning. For example, the Canada Revenue Agency ("CRA") has recently introduced a new program: the Related Party Initiative ("RPI"). This new audit initiative focuses on individual taxpayers with a net worth of more than $50 million or who have related groups comprised of 30 or more entities. CRA requires individuals to complete a T997 "Audit Query Sheet," as well as a meticulous 20-pages questionnaire, within 30 days of receipt.

CRA is also examining the use of trusts in tax planning at all income levels, and is gathering information about a variety of related economic entities, including partnerships, corporations, joint ventures, and private foundations. Hence while a corporation may not be directly targeted by an RPI audit, it could be connected indirectly to an audited individual as one of that individual's 30 entities.

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