Urgent Advisory: Commence Voluntary Disclosures Before The End Of 2015

Data from the Canada Revenue Agency ("CRA") confirms that voluntary disclosures ("VDs") of offshore assets, gains and income hit record levels in 2015.  This proliferation of VDs is attributable to various factors, including increased public awareness of:

• international tax compliance issues through media reports;
• the CRA's Offshore Tax Informant Program; and
• the imminent automatic exchange of international information under the common reporting standard.

However, the strongest impetus for the proliferation of offshore VDs may be the recent letter writing campaign by Swiss financial institutions, requiring confirmation that their clients are tax-compliant in their home jurisdiction. Foreign financial institutions, particularly Swiss-based, are now seeking written confirmation from Canadian taxpayers' professional advisors that the taxpayer is, or is becoming, tax compliant in Canada.