52 LEXPERT MAGAZINE
|
JUNE 2016
FEATURE
AS IF IT SOMEHOW
anticipated the Panama Papers leak the following month, the Liberal gov-
ernment announced in March that it would increase its budget allotment for the chronically underfunded
Canada Revenue Agency by about $90 million annually over the next five years.
Whether or not the CRA can actually make good on its vow that its half-billion-dollar bonanza will yield
$2.6 billion in recovered taxes through increased targeting of tax havens, stepped-up audits of large foreign
transfers of money and more intense investigation of consultants selling shelters remains to be seen.
But results are one thing and activity is another. And activity there will be: the CRA is hiring 100 new
auditors, increasing its audits of high-risk taxpayers fivefold to 3,000 annually from 600, and ramping up
its review of tax shelters to include 200 promoters a year, a tenfold increase over the current rate. e major
full-service firms are also beefing up in anticipation of an increased workload.
"It seems that every significant law firm in the country is setting up a tax litigation practice group," says
Guy Du Pont of Davies Ward Phillips & Vineberg LLP in Montréal. "It's a big growth area because govern-
ments are in need of money and they're going aer it more aggressively."
But tax boutiques like orsteinssons LLP, which have always been important players in this market, are
also preparing for growth.
"Recouping money that's going outside the country by focusing on offshore tax havens and aggressive tax
planning is where we'll see the most vigorous enforcement, and there's going to be a lot of litigation around
that," says Tom Boddez of orsteinssons in Vancouver.
DISPUTES
TAXING
With changing rules and a CRA budget increase
in an increasingly complex and costly tax dispute
resolution environment, tax litigation practice
groups anticipate a much bigger workload.
The lack of a unified tax court only complicates
matters further BY JULIUS MELNITZER
PHOTO:
SHUTTERSTOCK
