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Clamping down on corporate tax avoidance

Changes to EU corporate tax rules seek to increase revenues for national budgets and level the playing-field by closing loopholes used by some companies to avoid paying tax.

The new rules aim to prevent businesses exploiting national differences in taxation law to avoid paying their fair share.

Dating from 1990, the EU's parent-subsidiary directive was designed to eliminate the risk of double taxation for companies operating in different EU countries. However, some have used loopholes in the system to avoid paying tax on their cross-border payments.

Ending 'double non-taxation'

Companies are using hybrid loan arrangements specifically to exploit the current rules. These loans are treated either as tax-deductible debt payments or as tax-exempt dividends, depending on the country.

This can result in a tax deduction in one country, for the subsidiary, and exemption for the parent company in the other. This effectively means the company pays little or no tax on profits made by subsidiaries in certain countries.

The new rules will oblige companies to pay the tax due on incoming payments if it has been deducted elsewhere as a debt repayment. This should stop cross-border companies from planning their internal transfers specifically to benefit from this 'double non-taxation' loophole.

This issue is one where an EU-wide response is particularly appropriate – tackling it individually would put member governments at risk of losing tax revenue. It also means businesses will no longer be able to relocate or set up a subsidiary in another EU country purely to exploit differences in national rules.

Fighting tax evasion and avoidance

Corporate tax avoidance is high not just on the EU agenda but also internationally. It was discussed at recent G8 and G20 meetings where leaders endorsed the EU's action plan on tax fraud & evasion pdf - 105 KB [105 KB] .

Presented in December 2012, the plan sets out a comprehensive set of measures to help EU governments recoup the billions of euros lost through tax fraud and evasion.

As well as closing tax loopholes, the Commission is also working on a package including a taxpayers' code, an EU tax identification number, guidelines for tracing money flows and measures to curb tax havens.

Next steps

EU governments are expected to implement the amended rules and adopt an EU-wide anti-abuse law, a safeguard against abusive tax practices, by 31 December 2014.

International Aggressive Tax Avoidance and Tax Evasion

Canada's 2013 federal budget (Budget 2013) released on March 21, 2013 introduces a number of measures to strengthen the ability of the Canada Revenue Agency (CRA) to address international aggressive tax avoidance and to combat international tax evasion so as to maintain and protect Canada's tax base. These measures reflect the trend in other countries such as the United Kingdom, where the March 20, 2013 budget announced significant new measures on tax avoidance and tax evasion (including "name and shame") to increase tax compliance. These measures arrive at a time of increased social activism, media attention and political interest in one's "fair share" of taxes being paid internationally. Further, revising deficits and falling tax revenues may be a reason for the recent focus by tax administrations on tax abuse. The Forum on Tax Administration (FTA), which actively shares information among G20, OECD and non-OECD countries, has identified compliance with tax laws as a key challenge facing tax administrations in the 21st century.

Coincidentally, on April 4, 2013 the International Consortium of Investigative Journalists (ICIJ) released information gathered from an investigation into the world of offshore money, which investigation revealed a global tax evasion web of named individuals and groups, including 450 Canadians.

The CRA quickly responded to the media coverage of the ICIJ release and urged Canadians to provide information on suspected cases of tax avoidance or evasion through the existing Informant Leads Program and to take the opportunity, if necessary, to correct their own tax affairs through the use of the Voluntary Disclosure Program. In an announcement April 9, 2013, supported by a written request, the CRA called upon the ICIJ as well as to the Canadian Broadcasting Corporation (CBC) to provide the CRA with the information. Since the ICIJ has publicly stated that it will not provide any government agencies with access to the files that form the basis of its reporting, the CRA will need the Budget 2013 measures discussed below to address international tax non-compliance.

"Whistleblower" Program

Budget 2013 announced the CRA's intention to launch Stop International Tax Evasion Program (SITEP), a "whistleblower" program under which the CRA will pay rewards to individuals who provide information that identifies major international tax non-compliance. As noted above, currently the CRA accepts information under the Informant Leads Program, including information provided anonymously, but does not pay for the information.

Under SITEP, the CRA will enter a contract with an individual where information provided relating to major international tax non-compliance leads to the assessment and collection of additional taxes in excess of C$100,000. A payment for a percentage of the federal taxes collected will be made to the individual, subject to certain conditions, including:

all appeal rights associated with the assessed tax have expired

the federal tax has been collected

the information is not related to tax evasion for which the individual has been convicted

Anonymous submissions will not be accepted, although the identity of the individual who enters into a contract with the CRA will not be revealed without consent, to the extent possible under the law. The payments will range from 5% to 15% of the federal tax collected, based on the quality and extent of information provided. No payment will be made in respect of penalties, interest or provincial/territorial taxes. Payments will be included in taxable income in the year received and if the individual is a non-resident of Canada, will be subject to withholding tax.

This initiative follows the lead of other tax administrations, including those of the United States, the United Kingdom and Germany, who have been successful in detecting international tax non-compliance by paying for information. The CRA will provide further details regarding SITEP in the coming months.

International Electronic Funds Transfers

Currently, certain financial intermediaries must report international electronic funds transfers (EFTs) of C$10,000 or more to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. The financial intermediaries include banks, credit unions, caisses populaires, trust and loan companies, money service businesses and casinos. The EFT reports must be made within five working days after the day of transfer and contain detailed information.

Budget 2013 proposes that starting in 2015, financial intermediaries will be required to report international EFTs to the CRA in addition to FINTRAC. The CRA will develop a streamlined approach for the electronic submission of the report in consultation with the financial intermediaries.

The information will be used in the administration of the federal Income Tax Act (ITA), Excise Tax Act (ETA) and the Excise Act, 2001 (EA).

Information requirements regarding unnamed persons

Currently, the ITA, the ETA and the EA contain rules allowing the CRA to require third parties to provide information or documents for the purposes of verifying tax compliance by unnamed persons, subject to obtaining prior judicial authorization on ex parte application (i.e., without the CRA being legally required to notify the third party of the application). Budget 2013 proposes to eliminate the ex parte aspect of these applications and to require the CRA to give notice to the third party when it seeks judicial authorization. As a result, the third party will need to make submissions at the hearing of the application, rather than seeking a subsequent review of the original ex parte order. This new measure will apply on Royal Assent to the enacting legislation.

The stated rationale for this change is to speed up the audit process and allow the CRA faster access to information on unnamed individuals for the purposes of civil actions. It also addresses the lack of success of the CRA in such cases as Lordco Parts Ltd.1 and RBC Life Insurance Co.,2 where the Federal Court of Appeal imposed strict limitations on the Crown in ex parte requests.

Foreign reporting requirements

A Canadian-resident individual, corporation or trust that owns, and certain partnerships that own, at any time in a taxation year, specified foreign property (including foreign deposits and shares of foreign corporations) with an aggregate cost in excess of C$100,000 must file a Foreign Income Verification Statement (Form T1135) with the CRA. The purpose of this requirement is to enable the CRA to determine whether the taxpayer's foreign income has been reported correctly. The form is required to be filed even if the taxpayer has no tax payable during the year.

Effective for 2013 and subsequent taxation years, Budget 2013 proposes to extend the normal reassessment period for a taxation year of a taxpayer by three years if the taxpayer has failed to report income from a specified foreign property on the taxpayer's annual income tax return, and the taxpayer has not filed Form T1135 on time, has not identified a specified foreign property on Form T1135 or has improperly identified a specified foreign property on Form T1135. Budget 2013 also proposes to revise Form T1135 to be used in the 2013 and subsequent taxation years so that it requires taxpayers to include the name of the institution holding funds on the taxpayer's behalf outside of Canada, the country to which the property relates and the foreign income generated from the property. Budget 2013 indicates that starting in 2013, the CRA will remind taxpayers on their Notices of Assessment of the obligation to file Form T1135 if they have indicated on their income tax returns that they have specified foreign property in the taxation year with a total cost of more than C$100,000. Finally, the filing instructions on Form T1135 will be clarified, and CRA will develop a system that will allow Form T1135 to be filed electronically.

Treaty shopping

Canada continues to actively negotiate and conclude or amend tax treaties and tax information exchange agreements (TIEAs) to support international trade and investment and to combat international tax evasion and avoidance. In some circumstances, the benefits conferred under Canada's tax treaties are effectively enjoyed by residents of third countries that are not a party to the particular treaty, through the use of intermediaries or other means. This practice is referred to as "treaty shopping".

To date, challenges to treaty shopping generally have been unsuccessful in Canadian courts, whether based on the general anti-avoidance rule (GAAR) (see MIL Investments Inc.,3 discussed in Tax Update August 2009) or the "beneficial owner" of income approach (see Velcro Canada Inc.4 and Prévost Car Inc,5 discussed in Tax Update April 2012). The limitation on benefits provisions of the Canada-U.S. tax treaty as well as the anti-treaty shopping provision in each of the dividend, interest and royalty articles in other recent tax treaties such as the treaties with Hong Kong, New Zealand and Poland, are examples of other tools to challenge treaty shopping.

In Budget 2013, the government acknowledged its lack of success in court cases and announced its intention to consult on possible measures to protect the integrity of Canada's tax treaties while preserving a business tax environment that remains conducive to foreigninvestment. A consultation paper will be publicly released to provide an opportunity to comment on possible measures.

Reducing tax evasion and avoidance

Issue

The vast majority of UK individuals and businesses pay the tax that is due. However, there is a small minority who don't.

This imposes an unfair burden on the honest majority and prevents money from reaching the crucial public services that need it. We want to stop people cheating the tax system and collect more of what's owed.

The difference between the revenues that in HM Revenue & Customs' (HMRC) view should come in, and the total actually collected by HMRC, is known as the 'tax gap'. Tax evasion and tax avoidance by businesses and individuals contribute to the tax gap, along with error, failure to take reasonable care, non-payment, legal interpretation, the hidden economy and criminal attacks on the tax system.

The tax gap in the 2010 to 2011 financial year was estimated to be £32 billion – 6.7% of the total tax that HMRC estimates was due – and tax evasion and avoidance together accounted for £9 billion of this.

Actions

We are working to prevent evasion and avoidance, detecting it early where it arises, and counteracting it effectively through investigation and legal challenge.

We are investing in HMRC to prevent tax avoidance and evasion. In 2010 the government allocated HMRC £917 million from efficiency savings to reinvest in generating additional compliance revenues of £7 billion a year by 2015.

In the Chancellor's 2012 Autumn Statement, HMRC received a further £77 million for specific additional projects aimed at reducing evasion and avoidance.

At the G8 summit in June 2013 we announced steps towards achieving greater international tax transparency to prevent offshore tax avoidance and evasion.

Giving people opportunities to declare what they owe

We are running campaigns to encourage people to tell HMRC what they owe, before we track them down. So far, HMRC has raised £547 million from voluntary disclosures, and almost £140 million from follow-up activity including 20,000 completed investigations.

Prosecuting more people who break the law

HMRC is taking swifter legal action against those who don't come forward and sort out their taxes. We are also allocating more resources to increase the pace and number of tax evasion cases being brought before the criminal and civil courts.

We are setting up local task forces to identify and deal with tax cheats, using criminal and civil powers.

We are prosecuting more people who break the law by evading tax. We have recruited an additional 200 criminal investigators to increase the number of people prosecuted for tax evasion from 165 in 2010 to 2011, to 565 in 2012 to 2013, and to 1,165 in 2014 to 2015.

Preventing avoidance by large multinational corporations

Some multinational businesses avoid paying some taxes by shifting profits away from the location where the activities creating those profits take place - this is also known as base erosion and profit shifting (BEPS).

The international corporate tax standards have struggled to keep pace with changes in global business practices, with an increasing share of trade taking place online. International tax standards have remained largely unchanged for over a hundred years - and now need to be updated to prevent gaps from being exploited.

At the G20 meeting of finance ministers in February 2013, Chancellor of the Exchequer George Osborne welcomed the initial report by the international Organisation for Economic Co-operation and Development (OECD) on addressing BEPS as a first step for dealing with profit shifting by multinational corporations.

At the G8 summit in June 2013, G8 leaders called on the OECD to draw up a template for global corporations to report to tax authorities on where they make their profits and pay taxes around the world. This will give tax authorities around the world a new tool against tax avoidance by multinationals.

Alongside these efforts, we are also recruiting more people to speed up HMRC's work to identify risks relating to large businesses. This will help to make sure that multinationals fully declare their UK profits and pay the tax due in the UK.

Preventing avoidance and evasion by wealthy individuals

We are expanding HMRC's Affluent Unit, with 100 extra investigators and extra risk and intelligence staff to identify and deal with avoidance and evasion by the wealthiest individuals.

We are increasing the number of specialist personal tax inspectors to prevent evasion and avoidance of inheritance tax, using offshore trusts, bank accounts and other entities. These specialists will concentrate in particular on the agents and tax intermediaries involved in these activities.

Increasing our ability to identify offshore tax evasion and avoidance

We are working more closely with other tax administrations to prevent offshore evasion.

At the G8 Summit in June 2013, the UK reached a major new agreement with G8 member states to move to establish the automatic exchange of information between tax authorities. G8 countries agreed to work with the OECD to develop a model for this.

This builds on the prior commitment made by France, Germany, Italy, Spain and the UK to pilot the automatic exchange of tax information. This initiative has since been joined by 12 other EU Member States and Mexico and Norway.

The UK Crown Dependencies and Overseas Territories (Guernsey, the Isle of Man, Jersey , the Cayman Islands, Anguilla, Bermuda, the British Virgin Islands, Montserrat, Gibraltar and the Turks and Caicos Islands) have also joined this initiative, agreeing to automatically exchange information about accounts held in those jurisdictions with the UK and others.

We have also set up a new centre of excellence within HMRC to bring together and enhance our expertise in dealing with offshore evasion. The team will look at how HMRC can best use data to identify offshore tax evasion.

Using data and new technology

We are investing in our ability to use data and new and advanced technology to identify fraud and evasion risks. We have already brought in an extra £1.4 billion of tax revenue by investing £45 million in these activities.

We are improving HMRC's CONNECT analytical computer system, so that the department is better able to identify areas of compliance risk. This will allow HMRC to act swiftly in identifying and investigating fraudulent behaviour.

Dealing with tax avoidance schemes

We are designing legislation that minimises the scope for tax avoidance.

The government has introduced a General Anti-Abuse Rule (GAAR), aimed at deterring and preventing artificial and abusive tax avoidance schemes.

We will also introduce new measures to deal with tax advisers who sell contrived and aggressive tax avoidance schemes. The government has announced it will consult on proposals to introduce significant new information disclosure and penalty powers, to make it more difficult for the promoters of abusive schemes to continue to market them in the future.

We are using settlement opportunities to encourage users of avoidance schemes to agree their tax position with us, and investing in additional resource to accelerate litigation for those who do not settle.

We are making better use of anti-avoidance communications to influence the behaviour of taxpayers and promoters of avoidance schemes. We are also improving the quality of information available on avoidance to help taxpayers realise the potential downsides and risks.

Background

The 2010 document 'The Coalition: our programme for government' stated that the government will make every effort to prevent tax avoidance.

As part of Budget 2011 the government published 'Tackling tax avoidance' which set out our anti-avoidance strategy. The 3 principles are:

  • preventing avoidance at the outset
  • detecting it early where it persists
  • counteracting it through legislative change and challenge through litigation

    • At Budget 2012 (PDF) we announced new guidance on the General Anti-Abuse Rule (GAAR), following recommendations from a report into tax avoidance (PDF) led by Graham Aaronson in 2011. The guidance will come into affect with the Finance Act 2013, due to be published in summer 2013.

    In his December 2012 Autumn Statement, the Chancellor of the Exchequer said: 'There are still too many people who illegally evade their taxes, or use aggressive tax avoidance in order not to pay their fair share' and set out the government's commitment to taking action against these people.

    In December 2012 we published 'Closing in on tax evasion: HMRC's approach', which sets out our approach to tax evasion in more detail, concentrating particularly on how we will use third party data.

    In the 2013 Budget, HMRC published the report 'Levelling the tax playing field' which highlighted the successes HMRC has had in tackling avoidance, evasion, criminal attack and debt since 2010. HMRC also published its offshore evasion strategy 'No safe havens' which sets out HMRC's approach to tackling offshore evasion.

    At the G20 meeting of finance ministers in July 2013, Chancellor of the Exchequer George Osborne welcomed the OECD BEPS action plan to address profit shifting by multinational corporations. The action plan includes 15 specific proposals, which will be taken forward over the next two years.

    In 2011 to 2012 HMRC brought in a record £16.7 billion of additional revenues from compliance activities. HMRC also protected £2.5 billion of revenue by preventing organised criminal attacks, and defendants were convicted in 85% of criminal cases taken to court.

    The difference between tax avoidance and evasion

    Tax avoidance is bending the rules of the tax system to gain a tax advantage that Parliament never intended. It often involves contrived, artificial transactions that serve little or no purpose other than to produce a tax advantage. It involves operating within the letter – but not the spirit – of the law. Tax evasion is when people or businesses deliberately do not pay the taxes that they owe and it is illegal.

    Budget 2013 - Stop International Tax Evasion Program

    The Offshore Tax Informant Program (OTIP), announced in Economic Action Plan 2013 as the Stop International Tax Evasion Program, was launched on January 15, 2014. For more information, go to Offshore Tax Informant Program.

    The budget announces the CRA's intention to launch an initiative to encourage individuals to provide relevant information identifying international tax evasion and avoidance. Under the initiative, the CRA will enter into a contract with an individual where information is provided to the CRA that leads to the assessment and collection of additional taxes arising from major international tax non-compliance. A payment for a percentage of the federal taxes collected will be made to the individual, subject to certain conditions.

    Does the CRA currently accept information related to tax evasion?

    Yes. The CRA currently accepts information, including information provided anonymously, related to suspected tax evasion and ensures that it is reviewed and provided to the appropriate compliance program. The CRA does not pay for the information that it currently receives.

    What will be different under the initiative?

    Under the new initiative, the CRA will enter into a contract with an individual where information is provided to the CRA that leads to the assessment and collection of additional taxes arising from major international tax non-compliance. A payment for a percentage of the federal taxes collected will be made to the individual, subject to certain conditions. Anonymous submissions will not be accepted under this initiative.

    Will the CRA continue to accept all information concerning suspected tax evasion?

    Yes. While the initiative is being launched to encourage individuals to provide the CRA with information related to major international tax non-compliance, the CRA will continue to accept all information related to suspected tax evasion.

    Why is the CRA considering making payments for information that identifies major international non-compliance?

    Aggressive international tax evasion and avoidance is recognized as a significant ongoing problem, which is often difficult to identify and address. The CRA is evolving our approach and developing new tools to effectively combat tax evasion and avoidance. Furthermore, other tax administrations have encountered success in detecting international non-compliance by paying individuals for this information.

    What is considered major international tax non-compliance for the purposes of the initiative?

    Under the terms of the contract, the information related to the non-compliant activity must lead to the assessment or reassessment of additional federal taxes that exceed $100,000. Payments will be made only where the non-compliant activity involves foreign property or property located or transferred outside Canada, or transactions conducted partially or entirely outside Canada.

    What are the other conditions that must be met before a payment is made under the initiative?

    Under the terms of the contract, a payment will be made if certain conditions have been met, including the following:

  • all objection and appeal rights associated with the assessed tax have expired;
  • the federal tax, for which a payment is being issued, has been collected;
  • the information is not related to tax evasion for which the individual has been convicted.

    • Will the payment be taxable?

    A payment under the initiative will be included in taxable income in the year it is received. Individuals who are not resident in Canada for tax purposes at the time the payment is received will also be subject to tax on the payment.

    Will the identity of the individual who enters into a contract with the CRA be revealed?

    Unless the individual provides the CRA with consent to release his or her identity, the CRA has a legal obligation not to disclose any identification information. The CRA will protect the confidentiality of the individual's identity to the extent possible under the law.

    How much will the CRA pay for information that leads to the assessment and collection of additional taxes?

    A graduated payment rate from 5% to 15% of the federal tax collected will be used to determine the payment based on the quality and extent of information provided. No payment will be made in respect of penalties and interest or provincial taxes.

    How long will the entire process take before a payment is received?

    There are many factors that affect the length of time that it will take the CRA to evaluate a file and each case will be different. The CRA is prohibited from disclosing information concerning the progress of files, but an individual will be informed once they are eligible for a payment.

    When will this initiative start and how will a submission be made?

    The CRA will be making an announcement concerning the initiative with these details in the coming months. The announcement will include information concerning the process to follow if an individual wants to provide information under this initiative.

    Huge Cost of Tax Evasion Revealed as Campaign to Tackle Tax Havens Launches

    New research published by the Tax Justice Network shows that tax evasion costs governments around the world more than US$3.1 trillion annually.

    In Canada an estimated $81 billion a year is lost to tax evasion in the 'shadow economy' - that is half of our total healthcare spending. Canada ranks 11th out of the 145 countries surveyed in total amount of tax evaded.

    Tax havens are a major part of the tax evasion problem – and these new findings come as the Tax Justice Network launches Tackle Tax Havens, a new campaign that highlights the critical role that these secretive states play in corrupting the global economy.

    The issue of tax collection is rising fast up the political and social agenda, as countries across the world make deep cuts in public spending in ways that hurt the poor and themiddle classes the most.

    This new research demonstrates how important it is to tackle tax evasion and the tax havens that help wealthy individuals and corporations escape from contributing to the services that directly benefit them - from the health and education systems that support their workforces, to the roads that ship their goods to markets, to the courts of law that enforce their contracts or to the police who protect their property.

    But tax havens are not just about tax: they cause colossal damage on many fronts. Tackle Tax Havens aims to inform the public about the offshore system and the problems it causes -- and to show what we can do about it.

    Other key findings of the new report include:

  • Africa as a whole loses the equivalent of 98% of its total healthcare budget to tax evasion
  • 119 of the 145 countries surveyed are losing over half of their healthcare budget to tax evasion
  • In 67 countries, tax evasion losses are larger than their entire health budgets
  • In Bolivia, tax evasion is more than four times as large as that oil rich country's health spending. In Russia, it is more than three times the size
  • More than $1 in every $6 earned in the world is not subject to tax because those earning it have deliberately ensured that their income is hidden from the world's tax authorities
  • In Greece and Italy, where economic collapse currently looks possible, more than €1 in €4 is hidden in the shadow economy

    • Quotes:

    Dennis Howlett: Coordinator of Canadians for Tax Fairness

    "Canada needs to do more to curb tax havens and tax evasion, especially when deficit-cutting threatens to gut our social programs and undermine the ability of government to ensure food safety and environmental protection. A new study by the Tax Justice Network estimates that Canada is losing over $80 billion a year. That is more than half of all our health care spending. Going after resource extraction companies andCanadian banks, as well as many rich individuals who are taking advantage of tax havens to avoid paying taxes to Canada and to the developing countries where they are extracting resources, is a much better way to reduce the deficit than cutting spending on health, education and environmental protection."

    "Tackling tax havens is a crucial part of ending the culture of tax evasion. Tax evasion is crippling public finances across the world but governments aren't doing nearly enough to end this cancer."

    "Tax havens are engaged in economic warfare against the tax regimes of sovereign countries, and these estimates reveal the human cost in terms of the impact on health services."

    Richard Murphy of Tax Research UK, who undertook the research for the Tax Justice Network:

    "New data from the World Bank published last year on the size of countries' shadow economies let us prepare this estimate of tax lost to criminal tax evasion annually. The findings add a new policy agenda to public debate on the world's financial crisis. For example, Italy loses €183 billion to tax evasion a year. Its current debt of €1.9 trillion represents just over 10 years tax of tax evasion on this basis. If only more had been done to tackle rampant tax evasion, Europe would not be facing a crisis today."

    "Tax havens can be beaten using three simple measures. First we demand that all tax havens put details of the ownership of all companies and trusts located there, and the accounts of those organisations, on public record . Second we demand that all multinational companies publish accounts that reveal their use of tax havens. Last, we believe that all tax havens should be required to exchange information each year on the income recorded within them belonging to the citizens of other countries with the places where those people really live."

    "These measures would shatter the secrecy of tax havens for good, and that means those committing tax crimes will no longer have places to hide the proceeds of their crimes. Nothing could make a bigger contribution than this to solving the world's financial crisis right now."

    For more information:

  • Tackle Tax Havens website: www.tackletaxhavens.com
  • Campaign video: see below.
  • Canadians for Tax Fairness website: www.taxfairness.ca
  • Download full research findings and methodology: http://www.tackletaxhavens.com/Cost_of_Tax_Abuse_TJN_Research_23rd_Nov_2011.pdf
  • To discuss the research findings please contact Richard Murphy of Tax Research UK who undertook the research on behalf of the Tax Justice Networkrichard.murphy@taxresearch.org.uk / +447775 521 797
  • All other enquiries please contact : Dennis Howlett, Coordinator, Canadians for Tax Fairness at dennis.howlett@taxfairness.ca Cell: 613-863-3670
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