---------- Forwarded message ----------
From: David Amos <david.raymond.amos333@gmail.com>
Date: Tue, 13 Dec 2022 15:43:55 -0400
Subject: Fwd: Re The CRA in the news again Deja Vu anyone???
To: aammoscato@taxmco.com

---------- Forwarded message ----------
From: David Amos <david.raymond.amos333@gmail.com>
Date: Tue, 13 Dec 2022 15:34:59 -0400
Subject: Fwd: Re The CRA in the news again Deja Vu anyone???
To: imurphy@taxmco.com
Cc: motomaniac333 <motomaniac333@gmail.com>

https://www.cbc.ca/news/canada/windsor/cross-border-workers-cra-windsor-1.6682370

Ian Murphy is a tax partner with MCO Partners in Windsor. He says the
Canada Revenue Agency is under-staffed, under-trained and "broke,"
creating a massive backlog of cases. (TJ Dhir/CBC)


Comments
David Amos
I know I can help these nurses but I doubt they would believe me

 [Ian-Murphy]
IAN MURPHY
CPA, CA

519-253-6077 ext. 226


---------- Forwarded message ----------
From: David Amos <david.raymond.amos333@gmail.com>
Date: Fri, 7 Oct 2022 15:13:53 -0300
Subject: Re The CRA in the news again Deja Vu anyone???
To: dmilot@milotlaw.ca, contactus@taxationlawyers.ca,
acampbell@legacylawyers.ca, jdp@tdslaw.com, "Nathalie.Drouin"
<Nathalie.Drouin@justice.gc.ca>, Diane.Lebouthillier@parl.gc.ca,
"erin.otoole"<erin.otoole@parl.gc.ca>, pm <pm@pm.gc.ca>, premier
<premier@ontario.ca>, Newsroom <Newsroom@globeandmail.com>,
"jagmeet.singh"<jagmeet.singh@parl.gc.ca>, "Bill.Blair"
<Bill.Blair@parl.gc.ca>, "Brenda.Lucki"<Brenda.Lucki@rcmp-grc.gc.ca>,
mcu <mcu@justice.gc.ca>, nathalie.sturgeon@globalnews.ca,
"Jason.Proctor"<Jason.Proctor@cbc.ca>, "John.Williamson"
<John.Williamson@parl.gc.ca>, "Ross.Wetmore"<Ross.Wetmore@gnb.ca>,
"blaine.higgs"<blaine.higgs@gnb.ca>, "rob.moore"
<rob.moore@parl.gc.ca>, "Robert. Jones"<Robert.Jones@cbc.ca>,
"steve.murphy"<steve.murphy@ctv.ca>, "Melanie.Joly"
<Melanie.Joly@parl.gc.ca>, "Mark.Blakely"
<Mark.Blakely@rcmp-grc.gc.ca>, "martin.gaudet"
<martin.gaudet@fredericton.ca>, "Mitton, Megan (LEG)"
<megan.mitton@gnb.ca>, "michael.macdonald"
<michael.macdonald@thecanadianpress.com>
Cc: motomaniac333 <motomaniac333@gmail.com>, sheilagunnreid
<sheilagunnreid@gmail.com>, "silas.brown"<silas.brown@globalnews.ca>,
christian.lorenz@international.gc.ca

---------- Forwarded message ----------
From: "Lorenz, Christian"<Christian.Lorenz@cbsa-asfc.gc.ca>
Date: Fri, 7 Oct 2022 17:32:23 +0000
Subject: Automatic reply: Attn Jeff Pniowsky I was readig about you in
CBC today perhaps we should talk ASAP?
To: David Amos <david.raymond.amos333@gmail.com>

This email is not routinely monitored.

I am in my new role as Regional Director, Europe, Africa and Middle
East, and can be reached at: christian.lorenz@international.gc.ca
effective 15 August 2022.

Thank you.

**
Cette addresse courriel n'est pas surveillée régulièrement.

Je suis dans mon nouveau rôle comme Directeur Régional, Europe,
Afrique et Moyen-Orient, et peux être rejoint au:
christian.lorenz@international.gc.ca dés le 15 août 2022.

Merci.



---------- Forwarded message ----------
From: David Amos <david.raymond.amos333@gmail.com>
Date: Fri, 12 Mar 2021 15:00:03 -0400
Subject: Re The CRA in the news again Deja Vu anyone???
To: dmilot@milotlaw.ca, contactus@taxationlawyers.ca,
acampbell@legacylawyers.ca, jdp@tdslaw.com, "Nathalie.Drouin"
<Nathalie.Drouin@justice.gc.ca>, Diane.Lebouthillier@parl.gc.ca,
"erin.otoole"<erin.otoole@parl.gc.ca>, pm <pm@pm.gc.ca>, premier
<premier@ontario.ca>, Newsroom <Newsroom@globeandmail.com>,
"jagmeet.singh"<jagmeet.singh@parl.gc.ca>, "Bill.Blair"
<Bill.Blair@parl.gc.ca>, "Brenda.Lucki"<Brenda.Lucki@rcmp-grc.gc.ca>,
mcu <mcu@justice.gc.ca>
Cc: motomaniac333 <motomaniac333@gmail.com>, Nathalie Sturgeon
<sturgeon.nathalie@brunswicknews.com>, "Jason.Proctor"
<Jason.Proctor@cbc.ca>, "John.Williamson"
<John.Williamson@parl.gc.ca>, "Ross.Wetmore"<Ross.Wetmore@gnb.ca>,
"blaine.higgs"<blaine.higgs@gnb.ca>, "rob.moore"
<rob.moore@parl.gc.ca>, "Robert. Jones"<Robert.Jones@cbc.ca>,
"steve.murphy"<steve.murphy@ctv.ca>

https://davidraymondamos3.blogspot.com/2021/03/rcmp-threaten-bc-church-with-canada.html


Sunday, 7 March 2021
RCMP threaten a BC church with Canada Revenue Agency investigation???
NOW THATS TOO TOO FUNNY INDEED



https://www.cbc.ca/news/canada/british-columbia/cra-gross-negligence-demara-penalties-1.5945861

Canada Revenue Agency accused of blaming victims as 'gross negligence'
cases drag on


B.C. retiree who won appeal of $139K penalty claimed she didn't know
what was filed on her behalf
Jason Proctor · CBC News · Posted: Mar 11, 2021 5:45 PM PT

About the Author
Jason Proctor @proctor_jason
Jason Proctor is a reporter in British Columbia for CBC News and has
covered the B.C. courts and mental health issues in the justice system
extensively.


https://www.tdslaw.com/person/jeff-pniowsky/

Jeff Pniowsky
Jeff focuses his practice in the areas of tax litigation and dispute
resolution in the tax audit and appeals process, tax advisory
services, and complex commercial litigation.

    (204) 934-0586
    jdp@tdslaw.com


https://www.canlii.org/en/ca/tcc/doc/2021/2021tcc14/2021tcc14.html?searchUrlHash=AAAAAQAJdmFuY291dmVyAAAAAAE&resultIndex=3

Signed at Ottawa, Canada, this 2nd day of March 2021.

“Sylvain Ouimet”

Ouimet J.

CITATION:


2021 TCC 14

COURT FILE NO.:


2016-1686(IT)G

STYLE OF CAUSE:


MARGO DIANNE BOWKER

AND HER MAJESTY THE QUEEN

PLACE OF HEARING:


Vancouver, British Columbia

DATE OF HEARING:


February 10, 11, 12 and 13, 2020

REASONS FOR JUDGMENT BY:


The Honourable Justice Sylvain Ouimet

DATE OF JUDGMENT:


---------- Forwarded message ----------
From: David Amos <david.raymond.amos333@gmail.com>
Date: Fri, 7 Oct 2022 14:47:27 -0300
Subject: Fwd: Attn Jeff Pniowsky I was readig about you in CBC today
perhaps we should talk ASAP?
To: hmartinez@tdslaw.com, cdacosta@tdslaw.com
Cc: motomaniac333 <motomaniac333@gmail.com>

---------- Forwarded message ----------
From: Danielle Delorme <ddelorme@tdslaw.com>
Date: Fri, 7 Oct 2022 17:40:00 +0000
Subject: Automatic reply: Réponse automatique : Attn Jeff Pniowsky I
was readig about you in CBC today perhaps we should talk ASAP?
To: David Amos <david.raymond.amos333@gmail.com>

I will be out of the office Friday, September 30th and returning
Tuesday, October 11th.

I will not be checking emails during this time.


If you requrie assistance before October 11th, please contact either:

Colleen Da Costa   204-934-2340   cdacosta@tdslaw.com

Heather Martinez   204-934-2379   hmartinez@tdslaw.com


Thank you,

Danielle Delorme

Click the following link to unsubscribe or subscribe to TDS e-communications:

Unsubscribe at https://tdslaw.us3.list-manage.com/unsubscribe?u=980f278fbc816ab0f18183e01&id=cc57ea514c

Subscribe at https://www.tdslaw.com/subscribe/


---------- Forwarded message ----------
From: David Amos <david.raymond.amos333@gmail.com>
Date: Fri, 7 Oct 2022 14:32:11 -0300
Subject: Attn Jeff Pniowsky I was readig about you in CBC today
perhaps we should talk ASAP?
To: jdp@tdslaw.com, mcu <mcu@justice.gc.ca>
Cc: motomaniac333 <motomaniac333@gmail.com>, "Jason.Proctor"
<Jason.Proctor@cbc.ca>, "blaine.higgs"<blaine.higgs@gnb.ca>,
Diane.Lebouthillier@cra-arc.gc.ca, Andrew.LeFrank@cbsa-asfc.gc.ca,
Andrew.Baumberg@cas-satj.gc.ca, "Ellen.Desmond"
<Ellen.Desmond@crtc.gc.ca>, Christian.Lorenz@cbsa-asfc.gc.ca,
Allison.St-Jean@tc.gc.ca, media@tc.gc.ca, hc.media.sc@canada.ca,
mary-liz.power@canada.ca, media@cbsa-asfc.gc.ca,
Chris.Lorenz@cbsa-asfc.gc.ca, "christopher.rupar"
<christopher.rupar@justice.gc.ca>

https://www.cbc.ca/news/canada/new-brunswick/duty-to-document-nb-1.6608066

New Brunswick·CBC Investigates
How to keep secrets from the public: Don't write anything down


https://www.cbc.ca/news/canada/british-columbia/demara-tax-court-appeals-abuse-1.6608659

Judge slams CRA and Justice Department for 'egregious' conduct in epic
Tax Court battle


Decision likely to affect dozens of Canadians appealing gross
negligence penalties from tax agency

Jason Proctor · CBC News · Posted: Oct 07, 2022 4:00 AM PT |


A tax Court judge has slammed the Canada Revenue Agency for failing to
comply with pre-trial court rules and orders. (Chris Wattie/Reuters)

A Tax Court judge has slammed the Canada Revenue Agency and the
Justice Department for "egregious" conduct that threatened to deny
three taxpayers the right to a fair trial in an epic battle over
millions of dollars worth of tax penalties.

In a scathing decision that could have widespread implications, Judge
Patrick Boyle found the CRA committed an "intentional and deliberate"
pattern of ignoring court rules to "frustrate" the right that all
Canadians have to get a full picture of an opponent's case before
heading to court.

The three taxpayers — a Manitoba psychiatrist, an Ontario nurse and a
B.C. Air Canada pilot — were appealing three million dollars' worth of
gross negligence penalties levelled against them, for rejected returns
filed through a pair of disgraced tax consultancy firms.

But after years of pre-trial delays resulting from the CRA's repeated
failure to comply with his orders, Boyle took the extraordinary
measure of allowing the appeals without having a trial on the merits
of the case this week, to "protect the integrity of the judicial
process."

    Canada Revenue Agency accused of blaming victims as 'gross
negligence' cases drag on

"I find the [CRA's] egregious approach to pre-trial discovery in these
appeals to prejudice all three appellants who have been denied," Boyle
wrote in his ruling.

"These abuses of the discovery process ... have caused considerable
delay and expense to three Appellants in respect of their appeals.
They have also led to an inefficient use of public resources financed
by all Canadians."
'With great power comes great responsibility'

Boyle's decision is the latest chapter in a saga that has seen
hundreds of Canadians slapped with gross negligence penalties after
filing returns through DeMara Consulting and Fiscal Arbitrators.

The principals of both companies were jailed for tax fraud for
promoting schemes Boyle says "resemble in many respects the
de-taxation practices of sovereign citizens, though with less of the
non-fiscal cultish aspects."
Hundreds of Canadians filed appeals in Tax Court after the CRA
levelled gross negligence penalties against them in association with
returns filed through a pair of disgraced tax consultancies. (Minichka
/ Shutterstock)

According to court records, B.C.-based DeMara's scheme was called "the
remedy" and essentially involved claiming personal expenditures and
debts as expenses and capital losses for a non-existent business.

Canada's Income Tax Act gives CRA the ability to levy penalties
against Canadians who make false statements and omissions on their tax
returns, either knowingly or under circumstances that amount to gross
negligence.

The penalties in the DeMara and Fiscal Arbitrators case have reached
into the millions, leading to a huge backlog of appeals that have been
making their way through tax court since 2013.

    Tax agency obtains 'jeopardy order' for debt from Downton
Abbey-loving billionaire

Jeff Pniowsky, the Winnipeg-based lawyer who represented all three
plaintiffs, said fighting a decade-long court battle with the threat
of financial ruin hanging over their heads has cost his clients "years
of happiness."

"This was fundamentally a case about justice. Justice for the
taxpayers who had to endure years of gamesmanship and chicanery by one
of Canada's most powerful institutions: the CRA," Pniowsky told the
CBC.

Pniowsky, who has four children, said Boyle's ruling reminded him of a
line from one of his family's favourite superhero movies: Spiderman.

"With great power comes great responsibility," he said.

"It's clear from this case that the CRA and the Justice Department
have lost sight of that common-sense principle."
'Unprepared, unco-operative or untruthful'

Boyle's detailed 53-page ruling goes through the history of the case,
and the circumstances that led to each of the orders he found the CRA
later ignored.

The fight centred on pre-trial discovery, and the rights of the
taxpayers to examine a CRA representative or "nominee" who was
"knowledgeable" about their case.
The CRA has the ability to levy gross negligence penalties against
taxpayers who lie on their income tax forms. The penalties have been
devastating for some. (Graeme Roy/The Canadian Press)

The first person the agency put forward was "unaware of any criminal
investigation and had not informed himself" about any involvement of
the CRA's criminal investigators in the case.

The second nominee was a lead criminal investigator who "did not even
inform himself ... whether any investigation was undertaken of any of
these three appellants."

At one point, Boyle called the investigator "thoroughly unprepared,
unco-operative or untruthful."

The judge said the CRA and its lawyers twisted the words of an order
that boiled down to a demand for the agency to hand over any documents
relating to any investigations that touched on the three appellants.

"I variously described this as 'outrageously misleading and
inappropriate,''this might be contemptuous,' ... 'deeply, deeply
disturbed,''highly inappropriate' and 'I don't think you were
reasonably mistaken,'" Boyle wrote.

    It is an ex-reference: B.C. judge removes 'dead parrot' joke from
class-action ruling

The judge also zeroed in on the CRA's failure to tell the defence that
the second page of a three-page "Investigation Abort Report" against
one of the plaintiffs had gone missing. The report was handed over in
the middle of hundreds of documents. The missing page explained why a
criminal investigation was dropped.

The CRA claimed it had no "specific obligation" to point out missing
pages — a position Boyle found "shocking."

"Courts do not consider discovery to be a game, and it is particularly
disappointing when the Crown is the offending party," the judge said.

He said the omission gave credence to the idea the CRA "is hiding
something from them, from the Court and from Canadians about how these
investigations have been conducted.
'Stop, or I'll yell stop again!'

The judge pointed out that the CRA is "represented by the Department
of Justice which is essentially Canada's largest national law firm and
employs a large number of tax litigation lawyers who are wholly
familiar" with the court's rules.

Boyle said making yet another order for compliance would be pointless.
The judge compared his battle to get the CRA to comply with his orders
to a skit by Monty Python, whose troupe members are seen here from
left to right: John Cleese, Terry Gilliam, Terry Jones, Graham
Chapman, Michael Palin and Eric Idle. (PBS/Python (Monty) Pictures
Ltd./The Associated Press)

He was reminded of a skit by legendary English comedy troupe Monty Python.

"To make such an order would conjure up memories of the Pythonesque
skit of the British bobby of another era yelling at a scofflaw: 'Stop!
Stop!—Stop, or I'll yell 'stop' again!'" the judge wrote.

The three appeals were supposed to be the lead plaintiffs for a much
larger group of appeals. The judge said those people will have to
speak with their lawyers to determine how the ruling applies to them.

Pniowsky says he believes the decision is the first of its kind
against the CRA. He predicted fallout both in other DeMara and Fiscal
Arbitrators cases and in the wider world of tax litigation.

"Intoxicated with a sense of moral righteousness, the government
apparently determined or acted like these Canadians were not worthy of
basic procedural rights, thereby committing the same wrongs they
accused the taxpayers of: gross neglect, wilful blindness and at times
deceptive conduct," he said.
ABOUT THE AUTHOR
Jason Proctor

@proctor_jason

Jason Proctor is a reporter in British Columbia for CBC News and has
covered the B.C. courts and the justice system extensively.

CBC's Journalistic Standards and Practices


https://www.tdslaw.com/lawyers/jeff-pniowsky/

Jeff Pniowsky

Jeff focuses his practice in the areas of tax litigation and dispute
resolution in the tax audit and appeals process, tax advisory
services, and complex commercial litigation.

(204) 934-2586
jdp@tdslaw.com

Winnipeg
(204) 934-0586


Profile

Jeff is a partner with TDS who focuses his practice in the areas of
tax litigation and dispute resolution in the tax audit and appeals
process, tax advisory services, as well as complex commercial
litigation.  Formerly a senior Tax Litigator with the Federal
Department of Justice acting on behalf of the Canada Revenue Agency
(CRA) for almost 10 years, Jeff now serves local and national clients
with a wealth of experience in litigating at all levels of both the
Provincial and Federal courts, including the Supreme Court of Canada.

His work has included challenges to complex tax avoidance techniques
involving large corporate transactions, international taxation and
interpretation of tax treaties.  Jeff has advised the Aggressive Tax
Planning Division of CRA involving some of the most significant tax
matters in the Prairie region.  He also sat on the National Tax
Avoidance committee for Justice Canada.

In addition, Jeff has extensive experience dealing with tax
enforcement and other regulatory compliance issues including
disclosure requirements and was a member of national Documentary
Requirements Committee.  He is also considered an authority on
solicitor and client privilege issues relating to documentary
disclosure, having litigated several matters in this area as well as
being called upon to act as an adjudicator in a privilege
determination.


---------- Forwarded message ----------
From: David Amos <david.raymond.amos333@gmail.com>
Date: Sun, 7 Feb 2021 23:52:35 -0400
Subject: Diane.Lebouthillier and her old buddy John Ossowski should
remember my email and a couple of their own documents EH Madame
Desmond and Christian Lorenz ?
To: "Diane.Lebouthillier"<Diane.Lebouthillier@cra-arc.gc.ca>,
John.Ossowski@cbsa-asfc.gc.ca, megan.maloney@crtc.gc.ca,
bell.regulatory@bell.ca, martine.turcotte@bell.ca, Newsroom
<Newsroom@globeandmail.com>, Nathalie Sturgeon
<sturgeon.nathalie@brunswicknews.com>, "Nathalie.Drouin"
<Nathalie.Drouin@justice.gc.ca>, Norman Traversy
<traversy.n@gmail.com>, jswaisland@landingslaw.com,
Andrew.LeFrank@cbsa-asfc.gc.ca, Andrew.Baumberg@cas-satj.gc.ca
Cc: motomaniac333 <motomaniac333@gmail.com>, "Ellen.Desmond"
<Ellen.Desmond@crtc.gc.ca>, Christian.Lorenz@cbsa-asfc.gc.ca,
Allison.St-Jean@tc.gc.ca, media@tc.gc.ca, hc.media.sc@canada.ca,
mary-liz.power@canada.ca, media@cbsa-asfc.gc.ca,
Chris.Lorenz@cbsa-asfc.gc.ca, "christopher.rupar"
<christopher.rupar@justice.gc.ca>


 ----- Original Message -----
 From: martine.turcotte@bell.ca
 To: motomaniac_02186@hotmail.com
 Cc: bcecomms@bce.ca ; W-Five@ctv.ca
 Sent: Thursday, August 19, 2004 9:28 AM
 Subject: RE: I am curious

 Mr. Amos, I confirm that I have received your documentation. There is
 no need to send us a hard copy. As you have said yourself, the
 documentation is very voluminous and after 3 days, we are still in the
 process of printing it. I have asked one of my lawyers to review it
 in my absence and report back to me upon my return in the office. We
 will then provide you with a reply.

 Martine Turcotte
 Chief Legal Officer / Chef principal du service juridique
 BCE Inc. / Bell Canada
 1000 de La Gauchetière ouest, bureau 3700
 Montréal (Qc) H3B 4Y7

 Tel: (514) 870-4637
 Fax: (514) 870-4877
 email: martine.turcotte@bell.ca

 Executive Assistant / Assistante à la haute direction: Diane Valade
 Tel: (514) 870-4638
 email: diane.valade@bell.ca



A copy of this letter and all related correspondence will be added to
the public record of the proceeding.

If you have any questions or concerns, please feel free to contact me
at (613) 697-4027 or megan.maloney@crtc.gc.ca.

In the meantime, the Commission is currently continuing its review of
this costs application.

Yours Sincerely,

originally signed by

Megan Maloney
Legal Counsel

PIAC Welcomes New Board Members

Adds Expertise in Telecommunications, Broadcasting and Class Actions

OTTAWA – The Public Interest Advocacy Centre (PIAC), today announced
the recent election of four new directors to its Board, all experts in
either telecommunications, broadcasting or class actions:

    Konrad von Finckenstein is a lawyer and consultant based in
Ottawa. He was previously Chair of the Canadian Radio-television and
Telecommunications Commission (CRTC), an Honourable Justice of the
Federal Court of Canada and the Commissioner of Competition at the
Competition Bureau of Canada. In addition, he has held senior posts in
the Government of Canada in positions related to international trade,
telecommunications, competition and electronic commerce. Mr. von
Finckenstein has been elected as PIAC’s Chair of the Board.
    Suzanne Lamarre is a lawyer and engineer with the firm of
Therrien, Couture and is a former Commissioner of the CRTC. Maitre
Lamarre works in the areas of telecommunications, radiocommunications
and broadcasting law as a strategic advisor on regulatory and
governmental matters at both the national and international level.
    Monica Auer is a lawyer and the Executive Director of Canada’s
Forum for Research & Policy in Communications (FRPC), a non-partisan
organization focused on Canada’s communications system. She previously
worked at the CRTC and the Canadian Broadcasting Corporation (CBC).
Ms. Auer has been elected as PIAC’s Vice-Chair.
    Jonathan Schachter is a Toronto based lawyer with Sotos LLP, with
his practice areas including class actions, consumer protection
litigation, competition and price fixing, privacy litigation,
professional liability litigation, and trademarks and intellectual
property litigation and arbitration.

“PIAC’s extensive work on behalf of consumers before the CRTC requires
the utmost guidance and insight,” said John Lawford, Executive
Director and General Counsel of PIAC.  “We are therefore thrilled to
add to our Board persons with unparalleled experience to guide our
communications advocacy, as well as an expert in consumer class
actions as this sector becomes more litigious,” he added.

PIAC is a federally incorporated not-for-profit and registered charity
that advocates for consumer interests, and in particular vulnerable
consumer interests, in the provision of important public services.
PIAC is known for its representation of consumer, low-income and
seniors groups before the CRTC, arguing for better services, more
choice and consumer protection for customers of Internet, wireless,
telephone and broadcasting services.

For more information, please contact:

John Lawford
Executive Director and General Counsel
Public Interest Advocacy Centre (PIAC)
(613) 562-4002 ×25

> http://davidraymondamos3.blogspot.com/2017/02/re-fatca-nafta-tpp-etc-attn-president.html
>
> Tuesday, 14 February 2017
>
> RE FATCA, NAFTA & TPP etc ATTN President Donald J. Trump I just got
> off the phone with your lawyer Mr Cohen (646-853-0114) Why does he lie
> to me after all this time???
>
> ---------- Forwarded message ----------
> From: Michael Cohen <mcohen@trumporg.com>
> Date: Tue, 14 Feb 2017 14:15:14 +0000
> Subject: Automatic reply: RE FATCA ATTN Pierre-Luc.Dusseault I just
> called and left a message for you
> To: David Amos <motomaniac333@gmail.com>
>
> Effective January 20, 2017, I have accepted the role as personal
> counsel to President Donald J. Trump. All future emails should be
> directed to mdcohen212@gmail.com and all future calls should be
> directed to 646-853-0114.
> ________________________________
> This communication is from The Trump Organization or an affiliate
> thereof and is not sent on behalf of any other individual or entity.
> This email may contain information that is confidential and/or
> proprietary. Such information may not be read, disclosed, used,
> copied, distributed or disseminated except (1) for use by the intended
> recipient or (2) as expressly authorized by the sender. If you have
> received this communication in error, please immediately delete it and
> promptly notify the sender. E-mail transmission cannot be guaranteed
> to be received, secure or error-free as emails could be intercepted,
> corrupted, lost, destroyed, arrive late, incomplete, contain viruses
> or otherwise. The Trump Organization and its affiliates do not
> guarantee that all emails will be read and do not accept liability for
> any errors or omissions in emails. Any views or opinions presented in
> any email are solely those of the author and do not necessarily
> represent those of The Trump Organization or any of its
> affiliates.Nothing in this communication is intended to operate as an
> electronic signature under applicable law.
>
>
>
>
> ---------- Forwarded message ----------
> From: "Min.Mail / Courrier.Min (CRA/ARC)"<PABMINMAILG@cra-arc.gc.ca>
> Date: Wed, 24 May 2017 13:10:52 +0000
> Subject: Your various correspondence about abusive tax schemes - 2017-02631
> To: "motomaniac333@gmail.com"<motomaniac333@gmail.com>
>
> Mr. David Raymond Amos
> motomaniac333@gmail.com
>
>
> Dear Mr. Amos:
>
> Thank you for your various correspondence about abusive tax schemes,
> and for your understanding regarding the delay of this response.
>
> This is an opportunity for me to address your concerns about the way
> the Canada Revenue Agency (CRA) deals with aggressive tax planning,
> tax avoidance, and tax evasion by targeting individuals and groups
> that promote schemes intended to avoid payment of tax. It is also an
> opportunity for me to present the Government of Canada’s main
> strategies for ensuring fairness for all taxpayers.
>
> The CRA’s mission is to preserve the integrity of Canada’s tax system,
> and it is taking concrete and effective action to deal with abusive
> tax schemes. Through federal budget funding in 2016 and 2017, the
> government has committed close to $1 billion in cracking down on tax
> evasion and combatting tax avoidance at home and through the use of
> offshore transactions. This additional funding is expected to generate
> federal revenues of $2.6 billion over five years for Budget 2016, and
> $2.5 billion over five years for Budget 2017.
>
> More precisely, the CRA is cracking down on tax cheats by hiring more
> auditors, maintaining its underground economy specialist teams,
> increasing coverage of aggressive goods and service tax/harmonized
> sales tax planning, increasing coverage of multinational corporations
> and wealthy individuals, and taking targeted actions aimed at
> promoters of abusive tax schemes.
>
> On the offshore front, the CRA continues to develop tools to improve
> its focus on high‑risk taxpayers. It is also considering changes to
> its Voluntary Disclosures Program following the first set of program
> recommendations received from an independent Offshore Compliance
> Advisory Committee. In addition, the CRA is leading international
> projects to address the base erosion and profit shifting initiative of
> the G20 and the Organisation for Economic Co-operation and
> Development, and is collaborating with treaty partners to address the
> Panama Papers leaks.
>
> These actions are evidence of the government’s commitment to
> protecting tax fairness. The CRA has strengthened its intelligence and
> technical capacities for the early detection of abusive tax
> arrangements and deterrence of those who participate in them. To
> ensure compliance, it has increased the number of actions aimed at
> promoters who use illegal schemes. These measures include increased
> audits of such promoters, improved information gathering, criminal
> investigations where warranted, and better communication with
> taxpayers.
>
> To deter potential taxpayer involvement in these schemes, the CRA is
> increasing notifications and warnings through its communications
> products. It also seeks partnerships with tax preparers, accountants,
> and community groups so that they can become informed observers who
> can educate their clients.
>
> The CRA will assess penalties against promoters and other
> representatives who make false statements involving illegal tax
> schemes. The promotion of tax schemes to defraud the government can
> lead to criminal investigations, fingerprinting, criminal prosecution,
> court fines, and jail time.
>
> Between April 1, 2011, and March 31, 2016, the CRA’s criminal
> investigations resulted in the conviction of 42 Canadian taxpayers for
> tax evasion with links to money and assets held offshore. In total,
> the $34 million in evaded taxes resulted in court fines of $12 million
> and 734 months of jail time.
>
> When deciding to pursue compliance actions through the courts, the CRA
> consults the Department of Justice Canada to choose an appropriate
> solution. Complex tax-related litigation is costly and time consuming,
> and the outcome may be unsuccessful. All options to recover amounts
> owed are considered.
>
> More specifically, in relation to the KPMG Isle of Man tax avoidance
> scheme, publicly available court records show that it is through the
> CRA’s efforts that the scheme was discovered. The CRA identified many
> of the participants and continues to actively pursue the matter. The
> CRA has also identified at least 10 additional tax structures on the
> Isle of Man, and is auditing taxpayers in relation to these
> structures.
>
> To ensure tax fairness, the CRA commissioned an independent review in
> March 2016 to determine if it had acted appropriately concerning KPMG
> and its clients. In her review, Ms. Kimberley Brooks, Associate
> Professor and former Dean of the Schulich School of Law at Dalhousie
> University, examined the CRA’s operational processes and decisions in
> relation to the KPMG offshore tax structure and its efforts to obtain
> the names of all taxpayers participating in the scheme. Following this
> review, the report, released on May 5, 2016, concluded that the CRA
> had acted appropriately in its management of the KPMG Isle of Man
> file. The report found that the series of compliance measures the CRA
> took were in accordance with its policies and procedures. It was
> concluded that the procedural actions taken on the KPMG file were
> appropriate given the facts of this particular case and were
> consistent with the treatment of taxpayers in similar situations. The
> report concluded that actions by CRA employees were in accordance with
> the CRA’s Code of Integrity and Professional Conduct. There was no
> evidence of inappropriate interaction between KPMG and the CRA
> employees involved in the case.
>
> Under the CRA’s Code of Integrity and Professional Conduct, all CRA
> employees are responsible for real, apparent, or potential conflicts
> of interests between their current duties and any subsequent
> employment outside of the CRA or the Public Service of Canada.
> Consequences and corrective measures play an important role in
> protecting the CRA’s integrity.
>
> The CRA takes misconduct very seriously. The consequences of
> misconduct depend on the gravity of the incident and its repercussions
> on trust both within and outside of the CRA. Misconduct can result in
> disciplinary measures up to dismissal.
>
> All forms of tax evasion are illegal. The CRA manages the Informant
> Leads Program, which handles leads received from the public regarding
> cases of tax evasion across the country. This program, which
> coordinates all the leads the CRA receives from informants, determines
> whether there has been any non-compliance with tax law and ensures
> that the information is examined and conveyed, if applicable, so that
> compliance measures are taken. This program does not offer any reward
> for tips received.
>
> The new Offshore Tax Informant Program (OTIP) has also been put in
> place. The OTIP offers financial compensation to individuals who
> provide information related to major cases of offshore tax evasion
> that lead to the collection of tax owing. As of December 31, 2016, the
> OTIP had received 963 calls and 407 written submissions from possible
> informants. Over 218 taxpayers are currently under audit based on
> information the CRA received through the OTIP.
>
> With a focus on the highest-risk sectors nationally and
> internationally and an increased ability to gather information, the
> CRA has the means to target taxpayers who try to hide their income.
> For example, since January 2015, the CRA has been collecting
> information on all international electronic funds transfers (EFTs) of
> $10,000 or more ending or originating in Canada. It is also adopting a
> proactive approach by focusing each year on four jurisdictions that
> raise suspicion. For the Isle of Man, the CRA audited 3,000 EFTs
> totalling $860 million over 12 months and involving approximately 800
> taxpayers. Based on these audits, the CRA communicated with
> approximately 350 individuals and 400 corporations and performed 60
> audits.
>
> In January 2017, I reaffirmed Canada’s important role as a leader for
> tax authorities around the world in detecting the structures used for
> aggressive tax planning and tax evasion. This is why Canada works
> daily with the Joint International Tax Shelter Information Centre
> (JITSIC), a network of tax administrations in over 35 countries. The
> CRA participates in two expert groups within the JITSIC and leads the
> working group on intermediaries and proponents. This ongoing
> collaboration is a key component of the CRA’s work to develop strong
> relationships with the international community, which will help it
> refine the world-class tax system that benefits all Canadians.
>
> The CRA is increasing its efforts and is seeing early signs of
> success. Last year, the CRA recovered just under $13 billion as a
> result of its audit activities on the domestic and offshore fronts.
> Two-thirds of these recoveries are the result of its audit efforts
> relating to large businesses and multinational companies.
>
> But there is still much to do, and additional improvements and
> investments are underway.
>
> Tax cheats are having a harder and harder time hiding. Taxpayers who
> choose to promote or participate in malicious and illegal tax
> strategies must face the consequences of their actions. Canadians
> expect nothing less. I invite you to read my most recent statement on
> this matter at canada.ca/en/revenue-agency/news/2017/03/
> statement_from_thehonourabledianelebouthillierministerofnational.
>
> Thank you for taking the time to write. I hope the information I have
> provided is helpful.
>
> Sincerely,
>
>
> The Honourable Diane Lebouthillier
> Minister of National Revenue
>
>

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