Criminal investigations at the Canada Revenue Agency
The Canada Revenue Agency (CRA) is committed to taking action against those who wilfully do not comply with Canada’s tax laws by investigating serious tax crimes.
Overview
The CRA’s Criminal Investigations Program (CIP) plays a crucial role in protecting Canada’s tax base by investigating significant cases of tax evasion and other tax crimes. Where appropriate, the CIP refers cases to the Public Prosecution Service of Canada (PPSC) for possible criminal prosecution. Going after those who deliberately choose not to pay their taxes maintains public confidence in the Canadian voluntary self-assessment tax system.
The CRA is focusing on investigations that will have the greatest impact on compliance, namely:
- Significant cases of tax evasion with an international element
- Promoters of sophisticated and organized tax schemes
- Joint investigations with other enforcement agencies, including cases of tax evasion involving money laundering
- Significant cases involving income tax and/or Goods and Services Tax/Harmonized Sales Tax (GST/HST) tax evasion, including the underground economy
- Significant tax offences targeting benefits, credits, and false refunds
2019-2024 results achieved
135
convictions
58 taxpayers sentenced to prison for a total of more than 108 years
$25.1 millions
in court-imposed fines
Who we are
The CIP teams work from seven offices located across Canada. The work of the regional offices is supported by the Criminal Investigations Directorate in headquarters (HQ) which sets the priorities, policies, and strategic direction of the Program. It also provides other services such as investigative and legal expertise, as well as training, communications, and legislative support. Employees have expertise in various areas such as investigative techniques, digital forensics and informatics, criminal intelligence, evidence management, and data analysis.
The CIP currently employs 591 employees in the regions, complimented by over 127 employeesFootnote 1 in HQ.
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This map illustrates the number of employees by region for the CIP in Canada:
- Western (British Columbia, Alberta, Saskatchewan, Manitoba, Yukon Territory, Northwest Territories): 168
- Ontario: 271
- Headquarters (Ottawa): 127
- Quebec: 90
- Atlantic (Newfoundland and Labrador, Prince Edward Island, Nova Scotia, New Brunswick): 62
Spotlight – John, Senior Technical Specialist
From the moment I started working in the CIP in 1993, I found the type of work to be very challenging, but also very interesting and rewarding. You quickly learn that it’s not just about the numbers, but it’s about the story behind the numbers that counts in terms of making a successful referral to the PPSC. We heavily rely on team work to get the job done; and over the years, you develop close and meaningful relationships with your colleagues.
I have been involved in developing and delivering training at the regional and national level, so when I got the opportunity to become a member of the Training and Learning Section at HQ as a Senior Technical Specialist, I knew that was where I wanted to be since I very much enjoy interacting with newer investigators and assisting, in a small way, in their development.
When I started with the CRA, I recall that one of the facilitators kept referring to the CRA as a "learning organization". I truly believe this is even more relevant today given the influx of new staff and the knowledge and skills that they will need to be successful and ultimately deliver our program mandate for years to come.
Spotlight – Richard, Senior Computer Forensic Analyst (CFA)
Since 2016, I have been working as a CFA in Toronto, Ontario. In April 2023, I joined HQ to help facilitate the CFA program at the national level.
I wanted to become a CFA because it combines my love of technology with our innate desire for justice and fairness. As I grew older, my passions and career path gravitated towards technology. So, when the opportunity came to unite technology with criminal investigations, I jumped at the chance.
A CFA's daily workload consists of constant problem solving. As technology continues to evolve, the CFAs face a growing number of challenges with how electronic devices can be seized and analyzed. Encountering a wide range of devices, breaking passwords, bypassing encryption, and recovering deleted files are a regular part of the job. There is never a dull moment in the life of a CFA!
Spotlight – Harmeet, Senior Investigator
I embarked on my career journey as a CRA Investigator in 2020. I was fortunate to be assigned to a case at trial stage within the first few months of my tenure. Working closely with the PPSC, provided invaluable insights into the judicial complexities involved in successfully navigating cases at trial.
This early mentorship and leadership not only sharpened my focus on meticulous execution in a full-scale investigation, but also inspired my commitment to excellence. As I evolved in my role to a Senior Investigator, I got to leverage my experience and skill set as a lead investigator, assisting in various other cases and taking on multiple responsibilities within a complex case. Working in CIP, unlike conventional accounting roles, offers a unique blend of challenges and excitement. No two days are identical, and the fast-paced and agile nature of the job keeps me consistently engaged.
In CIP, we thrive by supporting one another and I am profoundly grateful to work in an exceptional program.
What we do
To achieve its goal of effectively addressing tax crimes, the CIP is legislated to investigate the following:
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Tax evasion
Investigations of this sort target criminals who deliberately do not file returns or pay their owed taxes. These types of investigations showcase the consequences Canadians face if they underreport or omit income from their tax returns. Tax evasion is an offence under section 239 of the Income Tax Act (ITA) and section 327 of the Excise Tax Act (ETA). Being convicted of tax evasion can include court-imposed fines ranging from 50% to 200% of the evaded tax and up to five years in prison.
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Tax offences targeting benefits, credits, and false refunds
Bad actors intentionally use criminal means to obtain various benefits, credits, and refunds, taking advantage of the systems put in place by the Government of Canada to help those who were legitimately in need of assistance. The CIP has the authority to investigate individuals who file false benefit returns to steal government funds. In addition, the CIP targets criminals who falsify records and claims, use two sets of financial records, claim personal expenses as business expenses, and inflate expenses to reduce taxes owed. This type of theft affects taxpayer confidence in the integrity of Canada’s tax system.
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Tax schemes
These investigations include tax promoters, and sometimes tax preparers, who coach their clients to violate Canada’s tax laws. These schemes can include not only domestic perpetration of tax evasion, but offshore schemes as well. Tax schemes are often complex in nature involving many transactions making them more challenging and time-consuming. It is important to note that just because someone holds money or assets offshore, it does not mean they are guilty of a tax crime.
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Money laundering
Money laundering is a process used to disguise the source of money or assets that come from illegal means. Since 2010, Canada recognizes tax evasion as a designated offence for money laundering. The CRA is therefore authorized to investigate money laundering cases that arise from tax crimes. The money laundering offence does not require that the person also be charged with the designated offence. However, in most CRA cases, the person would be charged under the ITA, ETA, or Criminal Code with tax evasion or other tax offenses. It is possible that an intermediary who facilitated the money laundering, who was not involved in the first crime, could be charged solely with a money laundering offence.
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Other crimes with a tax evasion nexus
Law enforcement authorities may approach the CRA when they are investigating serious crimes in which the CRA may have an interest and where they believe that taxpayer information would be relevant to their investigation. In these situations, a joint investigation between the CRA and the law enforcement authority can be initiated.
Subsection 241(9.5) of the ITA and subsection 295(5.04) of the ETA also allow the CRA to provide information to a police organization in specific circumstances and only when reasonable grounds exist that a serious offence has been committed.
Operational functions
Criminal investigations are executed in our regional offices. To ensure the smooth running of our operations, our teams in HQ are made up of experts in various fields to provide guidance and assistance to the investigative teams in each of the regions.
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Criminal intelligence
The Criminal Intelligence Section (CIS) team collects and analyzes external and internal data to identify new files and enhance existing leads and referrals by identifying patterns and schemes of criminal activity. They also support investigations in regional offices by analyzing and providing a mix of CRA data and intelligence that adds value to cases both at the workload stage and the investigation stage.
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Digital forensics
The Digital Forensics Services Section oversees the policies, procedures, and tools used in the identification, preservation, analysis, reporting, and scanning of paper and digital evidence within the context of criminal investigations.
This team also supervises the identification, research, testing, and procurement of hardware, software, and tools used by CFAs within the CIP. Our CFAs handle digital evidence and are involved in crypto-related activities. They support investigators in this capacity given the increase in the use of digital means in tax crimes and the increased use of digital currency to facilitate illegal transactions. As a result, CFAs and some of the CRA’s technology experts are securing tools that will assist with tracing these transactions. CFAs have expertise in both information technology and crypto to preserve digital evidence including data that may have been encrypted, password protected, or hidden by other electronic means.
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Investigations advisory services
The Investigations Advisory Services sections provides technical, accounting, policy and legal guidance, and support for criminal investigations of the ITA, ETA, and the Criminal Code for the regions and for senior management at HQ.
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Workload development and liaison services
The Workload Development and Liaison Services Section is responsible for managing the national workload development processes and promoting quality referrals to the CIP. The Section is also responsible for the development of its self-generated cases based on information provided by the CIS and external partners. In addition, the Section provides an enhanced liaison service to regional offices and stakeholders.
Criminal investigation process
Various sources of information may lead the CIP to initiate a criminal investigation. Criminal investigation cases may be triggered by referrals received from other CRA program areas, while some may be self-generated within the CIP based on leads received from various external partners.
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A pie graph showcasing the sources of criminal investigation cases. 37% are self-generated cases within the CIP, and 63% are referrals from CRA programs.
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A pie graph showcasing where leads for the CIP come from. 23% of leads are received from the Royal Canadian Mounted Police (RCMP), and 77% of leads are received from other law enforcement agencies.
Not all referrals and leads will trigger a criminal investigation. Whether or not a case is accepted by the CIP depends on many factors, including the availability of evidence and the reasonable prospect of a prosecution.
As of March 31, 2024, 175 investigations conducted by the CIP are ongoing.
As with any criminal investigation undertaken by law enforcement, the CRA’s criminal investigations can be complex and often require years to complete. A criminal investigation involves many steps such as gathering evidence, interviewing taxpayers and witnesses, executing search warrants, and analyzing evidence.
Between April 1, 2023, and March 31, 2024:
The CIP executed 59 search warrants
At least 115 devices and more than 26.5 terabytes of data were seized by CIP’s CFAs
The length of time required to investigate will be dependent on the complexity of the case, the number of individuals and/or corporations involved, the availability of evidence, the need for international requests for assistance, and the level of cooperation of witnesses.
In the course of a CRA criminal investigation, a report based on the results of the investigation is prepared by CRA investigators and sent to the PPSC when charges are believed to be warranted. It is the role of the PPSC to decide whether to pursue criminal charges under the ITA, ETA or Criminal Code, and to conduct criminal tax prosecutions.
There are 109 files where criminal charges were laid under the ITA, ETA and/or Criminal Code between April 1, 2019, and March 31, 2024.
Learn more about the criminal investigations process.
Partnerships at home and abroad
All provinces in Canada, as well as many countries around the globe, are facing a common threat posed by increasingly complex and innovative forms of tax crime. Therefore, the CIP recognizes the importance of strengthening its domestic and international partnerships.
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International partnerships
Organisation for Economic Co-operation and Development
The CRA is part of the Organisation for Economic Co-operation and Development (OECD) Task Force on Tax Crimes and Other Crimes (TFTC). The TFTC supports jurisdictions’ efforts to combat tax crimes through the implementation of the "Oslo Dialogue". This policy initiative launched in 2011 is used to promote a “whole of government” approach to fighting tax crime and other financial crimes through standard setting, sharing of best practices, and capacity building.
The TFTC meets twice a year to discuss emerging risks of tax crime, share knowledge and experiences within member countries, and to develop tools and products such as maturity models to assist tax administrations in being positioned for the future.
In addition, the CRA participates in the OECD’s Academy for Tax and Financial Crime Investigations (the Academy). The work of the Academy supports developing jurisdictions in their enforcement against tax and other financial crimes. The goal of the Academy is to provide law enforcement authorities with the resources and knowledge needed to combat tax and financial crime. The CRA provides the Academy with instructors for both virtual and in-person courses as a contribution to developing the tax crime prevention community internationally. In 2024, CRA instructors successfully participated in 8 different OECD academies. The instructors developed the modules content and facilitated the courses on a variety of topics such as international cooperation, major case management, human sources, net worths, and crypto currency.
Joint Chiefs of Global Tax Enforcement
The CRA is an active member of the Joint Chiefs of Global Tax Enforcement (J5), that brings together the criminal tax authorities of Australia, Canada, the Netherlands, the United States, and the United Kingdom. The J5 leads the fight against international tax crime and money laundering, including cryptocurrency threats and those who undertake, enable, or facilitate, global tax evasion.
Since the inception of the J5, leading data scientists, technology experts, and investigators from all J5 member countries have met together in events known as Challenges, aimed at developing operational collaboration. These Challenges include experts from each country with the mission of optimizing the usage of data acquired from a variety of open and investigative sources available to each country. The Challenges have proven to be quite effective for the J5, as they have generated significant leads for the organizations to investigate. In October 2023, the CRA was proud to have hosted the fifth J5 Challenge.
One of the great successes of the J5 has been the creation of the Global Financial Institutions Partnership (GFIP). The GFIP is an international public-private partnership, seeking to tackle tax crime by bringing together the J5 Chiefs and senior leaders in financial crime compliance from major international banks, banking representatives, and influential senior leaders from wider organizations. This partnership leverages capabilities and resources from both the public and private sectors to support the J5 mission. The GFIP gathers annually at a Summit, where key stakeholders gather to strategize, collaborate, and share insight and expertise on combatting financial crime in partnership. The fourth iteration of the GFIP Summit was held in Ottawa, Canada, in October 2024.
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National partnerships
National public-private partnership
The CRA has a domestic-level public-private partnership (PPP) with Canada’s major financial institutions, the Canadian Bankers Association, and the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), combined with several key representatives at the CRA from security, criminal investigations, and identity protection services. This working group focusses on discussing Canadian-based issues and brings together senior leaders and intelligence experts in financial crimes, to collaborate, share strategic-level information, and strengthen our combined capacity to combat tax crimes, such as tax evasion and money laundering. Through virtual discussions and annual in-person meetings, the working group also engages with other federal agency partners, including the Royal Canadian Mounted Police (RCMP), the Canadian Anti-Fraud Centre (CAFC), and the Canada Border Services Agency (CBSA), who are invited to meetings on specific topics of shared interest. Some of the key objectives of this national partnership are to discuss issues, develop threat assessments and typology reports, and share information that will increase our joint efforts to combat global threats, create networks to enhance our operations, and contribute to the GFIP.
Joint Forces Operations
Other national partnerships include, but is not limited to, Joint Forces Operations (JFO) with the RCMP and other Federal partners, such as CBSA and municipal and provincial police forces. The CIP enters into JFOs with law enforcement agencies to more effectively investigate specific cases where various offences are involved, for example: drug trafficking, money laundering and tax evasion. Aside from work on specific cases, members of the CIP are part of various working groups with domestic partners allowing for the exchange of ideas, and to discuss challenges. By working with our partners, the CRA’s CIP is able to share knowledge, expertise, and best practices making it easier to identify tax schemes and their participants. Through these partnerships, the CIP also achieves results, and enhances its capabilities to put global pressure on tax evaders in ways that it could not do on its own.
Criminal cases highlights
Thanks to the relentless efforts of our outstanding team of employees, the CIP achieved great successes over the past five years and was responsible for some key convictions, including:
Money laundering
A joint investigation by the CRA and the RCMP led to the conviction of 4 taxpayers involved in a money laundering network. The investigation revealed that the 4 individuals played a role in a system to launder money derived from illicit activities. They received heavy sentences:
One individual was sentenced to 9 years in jail and fined $928,234 and another individual was sentenced to 5 years in jail and fined $850,817. In addition, these two also had properties with an estimated value of $4.6 million confiscated as proceeds of crime.
A third individual was sentenced to 3 years in jail and was fined a total of $28,492.
A fourth individual was sentenced to $50,000 fine, an 18-month conditional sentence and 100 hours of community work.
Tax scheme
Four members of the same family were convicted for participating in a tax scheme. The investigation revealed that the individuals filed false GST/HST returns reporting over $56 million in sales and requesting over $3.6 million in refunds in an attempt to cheat the CRA.
In total, the four individuals were sentenced to 12 years in prison and more than $3.7 millions in fines.
Tax promoters
A taxpayer was sentenced to jail for participating in a fraudulent charitable donation scheme. The individual, who was a partner in a tax preparation business, claimed more than $34 million in false charitable donations on individual income tax returns prepared for over 30 clients.
The taxpayer fled Canada before authorities could prosecute him. The taxpayer was arrested upon his return to Canada and finally faced justice. The individual pleaded guilty to one count of fraud over $5,000 under the Criminal Code and was sentenced to a 3-year prison term.
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