Strategies, Solutions, & Insights to Today's Difficult Cross Border Tax Problems

David W. Chodikoff, LL.B., David Kerzner, LL.M., Ph.D., and Max Reed, B.C.L./LL.B.

This year, the International Consortium of Investigative Journalists (ICJC) leak yielded evidence of more than 200,000 offshore trusts, corporations, and individuals with unreported accounts in the past three years alone, estimated to hold in excess of $21 trillion. We have seen an unprecedented rise in the United States’ use of criminal prosecution to obtain taxpayer information in the form of John Doe summonses and non-prosecution agreements.

More recently, in Canada and globally, we’ve seen the implementation of the Foreign Account Tax Compliance Act (FATCA). And we’ve seen a string of major scandals involving some of the largest banks in the world, such as PMC, Paribas in France, Commerce Bank in Germany, many of the well-known Swiss banks, and, more recently, HSBC.

With the current global emphasis on offshore tax evasion, it is imperative that tax professionals are equipped with the best possible awareness of cross-border investments in the United States and Canada. This white paper, brought to you by Thomson Reuters Tax & Accounting Canada and incorporating the advice of industry experts, analyzes the implications of this increasingly litigious climate upon taxation professionals and their clients.

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