Report offshore tax cheating – After you submit

4. After you submit

All submissions are subject to a risk assessment, as well as an in-depth review to determine eligibility.

Evaluating an informant's submission

The CRA will conduct a preliminary review of your submission in order to:

• verify the identity of the Canadian taxpayer(s), (individual(s), corporation(s), or trust(s) that are the subject(s) of your submission;
• determine if your submission includes sufficient, specific and credible facts relating to the alleged international tax non-compliance; and
• verify your identity, as the informant(s);

The CRA will evaluate an informant's submission according to the following criteria:

• The informant is eligible. See Eligibility for more details.
• The information provided by the informant demonstrates that:
  • the tax non-compliance is international; and
  • the potential federal tax, excluding interest and penalties, is greater than $100,000.

Once the above criteria are met, a CRA analyst will consider the information provided by the informant, evaluate the merits of the case and make a recommendation. The informant's submission will be reviewed by a specialist in the area of offshore tax non-compliance in order to:

• verify the existence and determine the extent of the offshore non-compliance involving unreported foreign income and/or assets;
• ensure the CRA does not already have the Canadian taxpayer(s) under compliance action or have the information in its possession; and
• determine if  an offshore compliance audit of the Canadian taxpayer(s) is appropriate and/or whether the information will be shared with other CRA program areas for other possible enforcement-related actions.

If a case is recommended for inclusion in the reward program, it is referred to an internal committee of senior management representatives for approval to enter into a contract.

Entering into a contract

Once the submission is approved by the internal committee, the informant and the CRA will enter into a contract.

A payment can be denied and a contract can be terminated in certain situations, including where:

• the CRA already received the information from another source;
• an audit or criminal investigation is conducted but leads to an assessment of federal tax relating to international tax non-compliance that is less than $100,000;
• the taxpayer is successful in an administrative or judicial appeal resulting in an assessment of federal tax relating to international tax non-compliance that is less than $100,000; or
• less than $100,000 is collected because the taxpayer has no known assets that the CRA can use to settle the outstanding tax liability.

Files that do not meet the eligibility criteria are either closed or referred to other areas within the Agency. If that is the case, a letter will be sent to the informant.

Right of redress

The contract provides a dispute resolution process for informants. An informant's grievance will be reviewed by an internal review panel comprised of senior management representatives. Once the review is completed, the informant and the CRA will receive the panel's decision by mail.

Obtaining or receiving information about the status of a case

Because the Income Tax Act contains a general prohibition against the disclosure of taxpayer information, the CRA can only provide information to an informant on the status and disposition of their particular case. To ensure confidentiality, a request for an update on a case must be made in writing to the CRA and refer to the case number. The CRA will respond in writing and will only confirm whether a case is open or closed. As such, please do not contact the CRA for updates or to request information about a case.

An informant will receive written correspondence from the CRA only at their designated mailing address to acknowledge the submission, to initiate contract discussions, to inform them of a payment under the contract, and to serve notice of contract termination or completion.

Duration of the process

The CRA works to conclude the process as efficiently as possible. However, it may take several years from the date of entering into a contract with the CRA until the additional federal tax is assessed, the taxpayer's appeal rights have expired, and the amount owing is collected.