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ARTICLE · 27 JUNE 2014

Spring 2014 Auditor General’s Report – Aggressive Tax Planning

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The Auditor General released his spring report. Chapter 3 of the AG’s report dealt with the CRA’s approach to aggressive tax planning.

CanadaTax
John Sorensen
John Sorensen
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On May 6, 2014, the Auditor General ("AG") released his spring report.1 Chapter 3 of the AG's report dealt with the CRA's approach to aggressive tax planning ("ATP"), focusing on how the CRA manages its ATP program as well as how the Department of Finance responds to requests for new legislation to combat ATP. Overall, the AG concluded that the CRA's ATP program had tools to detect, correct and deter non-compliance. However, there is a need to evaluate the National Risk Assessment Model ("NRAM"), weaknesses in ATP performance measurements and a need to improve the monitoring of training.

The CRA has identified ATP as one of its highest compliance risks and administers an ATP program to identify tax avoidance arrangements and products and to administer the general anti-avoidance rule ("GAAR"). The AG's report identified four types of tax plans that were used for the AG's evaluations, namely:

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