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In October 2015, OECD released its BEPS Action 13, focused on new country-by-country (CbC) reporting requirements for large multinational enterprises (MNEs).

During recent months there has been a surge in cross-border M&A activity in which U.S. and non-U.S. companies combine in so-called inversion transactions.

As Canadian income tax residents are taxed on their worldwide income, the Government of Canada is concerned about the underreporting of "offshore" income.

Canadian residents are generally required to annually file a special information return for any year that they held, at any time in that year, "specified foreign property" that had a cost exceeding $100,000.

Lately I’ve noticed a number of articles regarding bank accounts held offshore by Canadian residents.

The IRS announced changes to two programs established to bring taxpayers into compliance with reporting and payment obligations related to offshore assets.

On July 22, 2016, the Tax Court of Canada released its highly anticipated decision in Gerbro v. R dealing with the offshore investment fund property rules in section 94.1 of the Income Tax Act.

In 280 BC the Greek King Pyrrhus won a decisive battle against the Roman army. However in winning the battle, Pyrrhus's army suffered great losses and when Rome had a chance to reconnoiter, it easily defeated what remained of the Greek's army.

The Cayman Islands, Nevis and the British Virgin Islands ("BVI") bring to mind images of turquoise waters, white sand beaches and…offshore bank accounts and corporations where the super wealthy stash their millions to avoid (and evade) taxes in their home countries.

Bill C-31 require Canadian financial institutions to implement procedures to enable identification of US reportable accounts.

The most significant Canadian tax technical bill in over a decade is now law, receiving royal assent on June 26, 2013.

Toronto Tax Lawyer Sabina Mexis discussed a CBC/Toronto Star investigation which looked into Canada's tax system...

The Foreign Account Tax Compliance Act (FATCA), enacted by the US Congress in 2010, becomes operational on July 1, 2014.

On February 5, 2014 Canada and the United States signed an Intergovernmental Agreement to implement the Foreign Account Tax Compliance Act.

As many of you know, our firm has been very active in the "FATCA" space.

Gone are the days when offshore bank accounts were outside the CRA's reach. With the advent of the CRS, CRA automatically receives financial information of Canadian taxpayers who own bank accounts or assets in other jurisdictions.