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2016 | OriginalPaper | Buchkapitel

6. The Role of Canada’s Tax Information Exchange Agreements in the Fight against Offshore Tax Evasion

verfasst von : David S. Kerzner, David W. Chodikoff

Erschienen in: International Tax Evasion in the Global Information Age

Verlag: Springer International Publishing

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Abstract

This chapter begins by reviewing the policy objectives behind tax information exchange agreements (TIEAs), while giving particular consideration to the objectives set by the OECD. The goals of Canada and the United States with respect to TIEAs are also reviewed. This chapter then examines how Canada’s TIEAs function as vehicles for the exchange of information (EOI) between Canada and foreign jurisdictions. Select articles dealing with the EOI process in Canada’s TIEAs are described and then compared against (1) the OECD Agreement on Exchange of Information on Tax Matters, (2) each other (i.e., other Canadian TIEAs in force), and (3) the TIEA between the United States and the Cayman Islands. The US–Caymans TIEA is used as an example of a US TIEA because of the Cayman Islands’ ongoing high-profile as a tax haven. By looking at Professor Steven Dean’s analysis of tax harmonization versus tax deharmonization, this chapter examines an important overarching question in the debate on effective EOI and the use of TIEAs regarding the global community’s focus on achieving a victory against international tax evasion through cooperation around the implementation of a uniform set of rules and procedures. The conclusion provides a summary of the results of the comparative analysis.

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Vorheriges Kapitel International Tax Enforcement in the United States

Nächstes Kapitel Article 26 of the OECD Model Tax Convention on Income and on Capital

See OECD, Agreement on Exchange of Information on Tax Matters (Paris: OECD, 2002) [treaty and commentary together: Model TIEA].

See Agreement between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland, including the Government of the Cayman Islands, for the Exchange of Information relating to Taxes (27 November 2001), online: http://www.oecd.org/unitedstates/35514531.pdf [US–Caymans TIEA].

The Cayman Islands was listed as one of the top five tax haven destinations for Canadian dollars with $25.8 billion invested in 2011: see Janet McFarland & Bill Curry, “Banking: Document Leak Reveals Widespread Use of Tax Havens” Globe and Mail (4 April 2013), online: http://fw.to/YW5XUuW.

See Model TIEA, above note 1, Preamble. The Model TIEA is presented as both a multilateral instrument and a model for bilateral treaties or agreements. This chapter examines the latter model, which is used by Canada and the United States.

See Canada, Department of Finance, “Tax Information Exchange Agreements,” online: www.fin.gc.ca/treaties-conventions/tieaaerf-eng.asp, where the full texts of Canada’s TIEAs can be found.

See Canada, Department of Finance, “Notices of Tax Treaty Developments,” online: www.fin.gc.ca/treaties-conventions/treatystatus_-eng.asp. For an excellent discussion of the history of Canada’s tax treaties, including an explanation of the use of tax treaties and important policy considerations, see Brian J Arnold, Reforming Canada’s International Tax System: Toward Coherence and Simplicity (Toronto: Canadian Tax Foundation, 2009) at 319–70.

See OECD, Global Forum on Transparency and Exchange of Information for Tax Purposes Peer Reviews: Canada 2011 — Combined: Phase 1 + Phase 2 (Paris: OECD, 2011) at 57–58, online: http://dx.doi.org/10.1787/9789264110458-en [Canada Peer Review Report].

See Chapter 3, Section 4.

OECD, Harmful Tax Competition: An Emerging Global Issue (Paris: OECD, 1998) at 24 [OECD 1998 Report].

See Robert T Kudrle, “The OECD’s Harmful Tax Competition Initiative and the Tax Havens: From Bombshell to Damp Squib” (2008) 8 Global Economy Journal 1 at 5.

OECD 1998 Report, above note 9 at 15.

See OECD, Improving Access to Bank Information for Tax Purposes (Paris: OECD, 2000) at 7. Without such records of financial transactions, a tax authority may be unable to determine and collect the correct amount of tax (ibid at 9). Denying access to bank records also greatly facilitates money laundering schemes that deal with the proceeds of crime to conceal their illegal origins (ibid at 25).

See ibid.

See ibid at 8.

See ibid.

Ibid at 13.

OECD 1998 Report, above note 9 at 24.

Adrian Sawyer, “Peer Review of Tax Information Exchange Agreements: Is It More Than Just about the Numbers?” (2011) 26 Australian Tax Forum 397 at 405, observing that the information exchange mechanism in TIEAs is fundamentally flawed.

See OECD, Tax Transparency 2011: Report on Progress (Paris: OECD, 2011) at 53.

See ibid.

See OECD, The OECD’s Project on Harmful Tax Practices: 2006 Update on Progress in Member Countries (Paris: OECD, 2006) at 2–3.

See ibid; OECD, OECD’s Current Tax Agenda (Paris: OECD, 2011) at 84. The Model TIEA emerged from work by the OECD to address harmful tax practices and develop a legal instrument that could be used to establish effective EOI: see Model TIEA, above note 1, Introduction at para 3. See also David E Spencer, “OECD Model Agreement Is a Major Advance in Information Exchange” (2002) 13 Journal of International Tax 1 (Checkpoint) at 2; Sawyer, above note 19 at 399.

See Model TIEA, above note 1, Introduction at para 3, citing OECD 1998 Report, above note 9.

See Spencer, above note 23 at 2. See also Nathan Boidman, “New TIEAs Extend the Playing Field for Canada’s Multinational Enterprises” (2010) 59 Tax Notes International 209 at 212 [Boidman, “New TIEAs”], describing Canada’s TIEA efforts to learn about Canadian account holders’ undisclosed income by rewarding tax haven jurisdictions with Canadian investment.

Sawyer, above note 19 at 403.

See ibid.

For a detailed review of the OECD’s tax haven lists, see Dries Lesage, “The G20 and Tax Havens: Maintaining the Momentum?” (Symposium on Governing the Global Economy: The Role of the G20, delivered at the University of Toronto, Munk School of Global Affairs, 18 June 2010) [Unpublished].

See Model TIEA, above note 1, Introduction at para 6.

OECD, Committee on Fiscal Affairs, Model Tax Convention on Income and on Capital (Paris: OECD, 1992) (loose-leaf) at Art 26, before 2005 [convention and commentary together: Model Tax Treaty].

See Vanessa Mock, “Luxembourg to Disclose Bank-Account Data” Wall Street Journal (11 April 2013). This move leaves Austria as the only EU member state that does not share foreign clients’ data with their home state. Austria believes that automatic information exchange involves a grave interference with individual privacy rights and, instead, remits a 35 percent withholding tax on interest income earned in Austrian banks, without disclosing the account holders’ identities: see David Jolly & James Kanter, “Austria, under Pressure, Defends Bank Secrecy Rules” New York Times (13 April 2013) B2, online http://nyti.ms/20Xp1Zn.

Enacted by Congress as part of the Hiring Incentives to Restore Employment (HIRE) Act, Public Law 111-147, and signed into law by the president on 18 March 2010 [FATCA]. See Mock, above note 31.

See Chapter 8.

On 15 March 2013, the Cayman Islands’ government announced that it would adopt the Model Intergovernmental Agreement to Improve Tax Compliance and to Implement FATCA (Model 1 IGA) in response to FATCA: see Patrick Temple-West, “Cayman Islands, Costa Rica Sign Pacts with U.S.” Reuters (29 November 2013), online: http://reut.rs/18skFED.

See United States, Congress, Joint Committee on Taxation, Explanation of Proposed Protocol to the Income Tax Treaty between the United States and Luxembourg (Washington, DC: Joint Committee on Taxation, 2011) at 22.

Ibid.

See Steven A Dean, “More Cooperation, Less Uniformity: Tax Deharmonization and the Future of the International Tax Regime” (2009) 84 Tulane Law Review 125 at 135–36 [Dean, “More Cooperation”], advocating economic cooperation in sharing tax revenues over tax harmonization.

See ibid at 136; Bruce Zagaris, “The Procedural Aspects of U.S. Tax Policy towards Developing Countries: Too Many Sticks and No Carrots?” (2003) 35 George Washington International Law Review 331 at 332–34.

See Steven A Dean, “The Incomplete Global Market for Tax Information” (2008) 49 Boston College Law Review 605 at 642 [Dean, “Incomplete Global Market”].

See United States, Congress, Joint Committee on Taxation, Explanation of Proposed Protocol to the Income Tax Treaty between the United States and Switzerland (Washington, DC: Joint Committee on Taxation, 2011) at 29.

See Canada, Department of Finance, The Budget Plan 2007 (Ottawa: Department of Finance, 2007), online: www.budget.gc.ca/2007/pdf/bp2007e.pdf, acknowledging that the “greatest challenges CRA faces in enforcing Canada’s tax laws are in respect of income earned in countries with which Canada does not have a tax treaty” (ibid at 243) and proposing to extend the exemption for dividends received out of active business income earned by foreign affiliates resident in treaty countries to also include active business income earned by foreign affiliates resident in countries that have agreed to a TIEA with Canada (ibid at 422). See also Boidman, “New TIEAs,” above note 25 at 212, describing Canada’s TIEA efforts to learn about Canadian account holders’ undisclosed income by rewarding tax haven jurisdictions with Canadian investment; Sandra Slaats, “Financing Foreign Affiliates: An Overview of the Canadian Proposals and the Rules in Selected Countries” (2007) 55 Canadian Tax Journal 676 at 679, observing that although the rationale for extending exempt surplus status to countries willing to sign a TIEA, including pure tax havens, is not exactly clear, it may be motivated by the desire to obtain information to combat tax evasion by Canadian individual investors.

See Jinyan Li, Arthur Cockfield, & J Scott Wilkie, International Taxation in Canada — Principles and Practices, 2d ed (Markham, ON: LexisNexis, 2011) at 380. For further policy discussion surrounding interest deductions and the exempt surplus regime, see Arthur J Cockfield, “Finding Silver Linings in the Storm: An Evaluation of Recent Canada–US Crossborder Tax Developments” CD Howe Institute Commentary No 272, Tax Competitiveness Program (September 2008) at 10, online: www.cdhowe.org/pdf/Commentary_272.pdf, observing that in 2007 Ottawa had initially proposed denying interest deductions for any interest expense that could be traced to earnings-exempt foreign sourced income. See, generally, Tim Edgar, Jonathan Farrar, & Amin Mawani, “Foreign Direct Investment, Thin Capitalization, and the Interest Expense Deduction: A Policy Analysis” (2008) 56 Canadian Tax Journal 803, discussing interest deductibility restrictions relating to both inbound and outbound investment and comparing the approaches of multiple jurisdictions. For a technical review of double dips and the revised proposal on interest deductibility, see Geoffrey S Turner, “Finance’s May 14, 2007 Revised Interest Deductibility Proposals — An ‘Anti-double-dip Initiative’” Tax Topics (5 July 2007) 1 at 1.

See Advisory Panel on Canada’s System of International Taxation, Final Report: Enhancing Canada’s International Tax Advantage (Ottawa: Department of Finance, 2008) at 27 [Advisory Panel on International Taxation].

See ibid.

See Canada, Department of Finance, News Release, “Canada Signs Tax Information Exchange Agreement with Liechtenstein” (31 January 2013), online: http://news.gc.ca/web/article-eng.do?nid=718269. While in the sense that many of these countries have high tax rates and would not be ideal locations for tax evaders, it is true that they are not tax havens, the treaty list includes a number of jurisdictions widely regarded as tax havens, including countries where EOI may be useful to combat other crimes such as money laundering and terrorism (e.g., Austria, Cyprus, Luxembourg, Pakistan, and the United Arab Emirates).

For a list of the eighty double tax conventions that Canada has signed and that do not contain either para 5 (anti–bank secrecy clause) or para 4 (which obligates a requested state to obtain the requested information even if it does not need that information for its own tax administration purposes) of Art 26 of the Model Tax Treaty, above note 30, see OECD, Global Forum on Transparency and Exchange of Information for Tax Purposes, “OECD Canadian Agreements,” online: Exchange of Tax Information Portal www.eoi-tax.org/jurisdictions/CA#agreements.

Arnold, above note 6 at 320–21.

Ibid: Professor Arnold explains that before the enactment of the foreign affiliate rules, Canada-based multinational enterprises could repatriate profits from foreign corporations on an exempt basis. However, under the new foreign affiliate rules (which required foreign affiliates to be residents of and doing business in countries with which Canada had a tax treaty), continuing this economic treatment would be very difficult, and hence the exigency to expand the Canadian treaty network.

See H Kerr, K McKenzie, & J Mintz, eds, Tax Policy in Canada (Toronto: Canadian Tax Foundation, 2012); ch 12 at 40–41.

Arnold, above note 6 at 322, observing that if Canada adopted a complex exemption system, this would eliminate the need to enter into a tax treaty with every jurisdiction that a Canadian company carries on active business with.

Ibid.

Ibid. See also Income Tax Act, RSC 1985, c 1 (5th Supp) [Act].

For a detailed explanation of the foreign affiliate regime, see, generally, Angelo Nikolakakis, Taxation of Foreign Affiliates (Toronto: Carswell, 2000) (loose-leaf).

See Advisory Panel on International Taxation, above note 43 at 22. These rules apply where the Canadian taxpayer, either alone or with related investors, owns at least a 10 percent direct or indirect interest in any class of shares of the foreign corporation (ibid at 21).

See Nathan Boidman, “Draft Regs for Novel Use of TIEAs” (2008) 51 Tax Notes International 228 [Boidman, “Draft Regs”].

See Advisory Panel on International Taxation, above note 43 at 21.

See Boidman, “Draft Regs,” above note 55 at 228.

See Boidman, “New TIEAs,” above note 25 at 210. However, as Edgar, Farrar, & Mawani, above note 42 at 7, and others have noted, with the new extension of exempt surplus status to TIEAs, which are primarily being signed with jurisdictions that have little to no income tax, the presence of a tax treaty has become a poor proxy for a level of tax in a foreign country sufficient to justify exempt treatment.

See Edgar, Farrar, & Mawani, above note 42 at 7.

See Kerr, McKenzie, & Mintz, above note 49 at 12:40.

See Boidman, “New TIEAs,” above note 25 at 210: “In other words, for Canadian-based MNEs that, in general, are fully compliant with Canada’s tax laws, the significance of the signing of the TIEAs has nothing to do with information that will be exchanged thereunder. Rather, TIEAs can serve to make such countries an attractive place for Canadian companies to carry on business.” An interesting parallel to note is that, as Professor Arnold observes, above note 6 at 321, the primary impetus behind Canada’s entering into tax treaties after 1972 was the exemption for dividends from foreign affiliates.

See Boidman, “New TIEAs,” above note 25 at 210–11. See also Patrick Marley & Susan Wooles, “Canada’s Tax Information Exchange Agreements: Impact on Tax Planning” (2010) 39 Tax Management International Journal 606 at 606–8.

See Canada, Department of Finance, “Tax Treaties and Tax Information Exchange Agreements,” online: Canada’s Economic Action Plan http://actionplan.gc.ca/en/initiative/tax-treaties-and-tax-information-exchange-agreements.

See ibid.

See Kerr, McKenzie, & Mintz, above note 49 at 12:40. See also Arnold, above note 6 at 322.

See Advisory Panel on International Taxation, above note 43 at 27.

Peter Blessing has used tables to compare provisions in the double tax conventions of the United States, and the use of tables to compare Canada’s TIEAs in this section is inspired by Blessing’s approach: see RE Andersen, Analysis of United States Income Tax Treaties (Thomson Reuters/WG&L, with updates through August 2015) (Checkpoint) (Blessing is the original author of this work). The legal instruments examined here, TIEAs, are altogether different from those examined in Blessing’s work, and the format of the tables, organization of the data, and analysis are original to this study.

Model TIEA, above note 1 at Art 1.

United States, Internal Revenue Service, United States Model Income Tax Convention (Washington, DC: Department of the Treasury, 2006) at Art 26, online: www.treasury.gov/press-center/press-releases/Documents/hp16801.pdf [convention and technical explanation together: US Model Tax Treaty].

See Model TIEA, above note 1, Commentary to Art 1 at para 2.

See ibid, Commentary to Art 1 at para 6.

See ibid, Commentary to Art 1 at para 3.

See ibid. In accepting this standard, the contracting parties acknowledge that information may be requested during an ongoing investigation and before the arrival of a definite assessment of the value of that information to the investigation: see ibid, Commentary to Art 1 at para 4; Canada Peer Review Report, above note 7 at 52.

See Model TIEA, above note 1, Commentary to Art 1 at para 3.

Canada Peer Review Report, above note 7 at 54. See also Model Tax Treaty, above note 30, Commentary to Art 26.

USC 26 (1986) of 1986, as amended, and the Treasury Regulations issued thereunder at Chapter 4. See also US Model Tax Treaty, above note 70 at Art 26.

Model TIEA, above note 1 at Art 2.

See Model TIEA, above note 1, Commentary to Art 2 at para 7. Article 7 (Possibility of Declining a Request) may apply (see ibid).

<Emphasis Type="Italic">US–Caymans TIEA, above note 2 at Art 2.

Model TIEA, above note 1 at Art 3.

See ibid, Commentary to Art 3.

See ibid, Commentary to Art 3 at para 9.

See ibid, Commentary to Art 3 at para 8.

See ibid, Commentary to Art 3 at para 14.

See ibid, Commentary to Art 3 at para 11.

Ibid at Art 4.

See ibid, Commentary to Art 4 at paras 16, 19, & 20.

See ibid: the term “person” also includes organizational structures such as unincorporated associations.

See ibid, Commentary to Art 4 at paras 21 and 38.

Model Tax Treaty, above note 30.

See ibid, Commentary to Art 4 at para 32.

See ibid.

See Model TIEA, above note 1, Commentary to Art 4 at para 33.

See ibid.

See ibid, Commentary to Art 4 at para 38.

Ibid at Art 5.

See Canada Peer Review Report, above note 7 at 54.

See Model TIEA, above note 1, Commentary to Art 5 at para 39.

100

26 September 1980 (as amended to the protocols signed on 14 June 1983, 23 March 1984, 17 March 1997, 29 July 1997, and 21 September 2007) at Art 27 (EOI). See also Model Tax Treaty, above note 30 at Art 26 (EOI).

101

See Model Tax Treaty, above note 30, Commentary to Art 26 at para 9.

102

See ibid.

103

See Model TIEA, above note 1, Commentary to Art 5 at para 39.

104

See ibid, Commentary to Art 5 at para 40.

105

See Canada Peer Review Report, above note 7 at 56.

106

See Model TIEA, above note 1, Commentary to Art 5 at paras 41–42.

107

See ibid, Commentary to Art 5 at para 43.

108

See Canada Peer Review Report, above note 7 at 55.

109

See Model TIEA, above note 1, Commentary to Art 5 at para 44.

110

See ibid.

111

See ibid, Commentary to Art 5 at para 46.

112

See ibid, Commentary to Art 5 at paras 50–51.

113

Regarding the Act, above note 52, see Chapter 4, Section 11. See also Canada Peer Review Report, above note 7 at 51 and 57.

114

See Canada Peer Review Report, above note 7 at 55.

115

See Model TIEA, above note 1, Commentary to Art 5 at paras 50–51.

116

See ibid, Commentary to Art 5 at para 57.

117

See ibid. As an example, a party that is seeking account information but lacks the name of the account holder may be permitted to provide an account number or similar identifying information: see ibid, Commentary to Art 5 at para 58.

118

See ibid, Commentary to Art 5 at para 62.

119

See ibid, Commentary to Art 5 at para 63.

120

See ibid, Commentary to Art 5 at para 64.

121

See Canada Peer Review Report, above note 7 at 57.

122

Ibid at 54.

123

See Model TIEA, above note 1, Commentary to Art 5 at para 65.

124

See Canada Peer Review Report, above note 7 at 64.

125

Model TIEA, above note 1 at Art 6.

126

See ibid, Commentary to Art 6 at para 66.

127

See ibid.

128

See ibid.

129

See ibid, Commentary to Art 6 at para 67.

130

Ibid at Art 7.

131

See ibid, Commentary to Art 7 at para 71.

132

See ibid, Commentary to Art 7 at para 72.

133

See ibid, Commentary to Art 7 at para 76.

134

See ibid at Art 5(5)(f); Section Commentary on Article 5, above in this chapter.

135

See Model TIEA, above note 1, Commentary to Art 7 at para 82.

136

See ibid, Commentary to Art 7 at para 81.

137

See ibid, Commentary to Art 7 at para 85. Regarding the definition and scope of the solicitor-client privilege under Canadian law, see Solosky v Canada, [1980] 1 SCR 821; Canada (MNR) v Reddy, 2006 FC 277.

138

See Model TIEA, above note 1, Commentary to Art 7 at para 91.

139

See ibid, Commentary to Art 7 at para 93.

140

Ibid at Art 8.

141

Arthur J Cockfield, “Protecting Taxpayer Privacy Rights under Enhanced Cross-border Tax Information Exchange: Toward a Multilateral Taxpayer Bill of Rights” (2010) 42 University of British Columbia Law Review 420 at 468, advocating appropriate technology solutions and the adoption of a multilateral agreement on taxpayer rights to safeguard transferred tax information with a minimum level of legal protection, including for taxpayer privacy rights, to ensure fairness in exchanges of taxpayer information.

142

See Canada Peer Review Report, above note 7 at 61.

143

See ibid. Section 241 of the Act, above note 52, strictly controls the use of taxpayer information obtained for the purposes of the Act and is subject to a narrow list of exceptions including disclosure under a tax treaty or TIEA. It contains penalties for violations, including imprisonment for up to one year.

144

Canada Peer Review Report, above note 7 at 63.

145

See Model TIEA, above note 1, Commentary to Art 8 at para 94.

146

See ibid.

147

See ibid, Commentary to Art 8 at para 97.

148

Dean, “More Cooperation,” above note 37 at 127.

149

Ibid at 139. As using the same language offers no assurance that tax laws will be interpreted and applied in an identical fashion, to achieve true tax harmonization, two or more nations would have to achieve a high degree of uniformity with respect to tax laws, tax rates, and the administration of those laws (ibid).

Ibid at 150.

Ibid.

Ibid at 153.

Ibid.

Ibid.

Ibid.

Ibid at 154.

Ibid at 157.

Ibid at 133.

See ibid at 144: “The Benefits Principle assigns the right to tax active (business) income primarily to the source jurisdiction, while the right to tax passive (investment) income is assigned primarily to the residence jurisdiction,” citing Reuven S Avi-Yonah, “International Taxation of Electronic Commerce” (1997) 52 Tax Law Review 507 at 509.

160

For a list of other countries (e.g., Germany and the United Kingdom) that have moved to an automatic EOI or withholding system, and away from a pure information by request model, in addition to current developments in this area, see Chapter 3, Section 6.1 (e.g. Germany, UK). See also Chapters 8 and 9.

Titel: The Role of Canada’s Tax Information Exchange Agreements in the Fight against Offshore Tax Evasion
verfasst von: David S. Kerzner
David W. Chodikoff
Verlag: Springer International Publishing
Buch: International Tax Evasion in the Global Information Age
Print ISBN: 978-3-319-40420-2

Electronic ISBN: 978-3-319-40421-9

Copyright-Jahr: 2016
DOI: https://doi.org/10.1007/978-3-319-40421-9_6

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