Voluntary Disclosure Team Section Content 1 Natasha MiklaucicPartner416.367.6233NMiklaucic@blg.com Salvatore MirandolaPartner416.367.6097SMirandola@blg.com Charles MarquettePartner514.954.3121CMarquette@blg.com Natasha Miklaucic, Salvatore Mirandola and Charles Marquette are tax lawyers and combined have more than 50 years of experience helping taxpayers take advantage of the CRA's Voluntary Disclosures Program. They have deep expertise with voluntary disclosures ranging from the most basic to the most complex. Over the course of their practices, they have successfully completed disclosures for over 200 taxpayers. Together, they have helped taxpayers avoid penalties, reduce interest and avoid jail time. With them you get the exceptional and highly efficient service at competitive rates. Natasha, Salvatore and Charles would be pleased to have a call or meet with you for a free consultation to discuss whether the voluntary disclosure process is right for you. Natasha, Salvatore and Charles are leaders in the tax community and are frequent speakers and writers on the voluntary disclosure process. They can assist you by:Drafting the required submission and filing it in a way that minimizes risk and reduces the overall amount you would otherwise be required to pay by obtaining relief from interest as well as penalties;Utilizing in-depth knowledge of the Income Tax Act (Canada) to minimize the amount tax that you will be required to pay; andKeeping your communications privileged — lawyers are subject to solicitor-client confidentiality on all communications, and generally cannot be compelled to release this information to anyone. Summary Section Content 2The Canada Revenue Agency (“CRA”) has recently increased its efforts to suppress tax evasion. The move by the CRA follows some high profile news reports indicating that a large number of Canadian taxpayers hold unreported funds in foreign financial institutions. The Voluntary Disclosures Program (sometimes referred to as the Canadian Tax Amnesty program) is an important procedure that can be undertaken in order to minimize, if not eliminate, the possibility of a penalty assessment and prosecution by the CRA – something that can happen at any time.You may be eligible to take advantage of the voluntary disclosures program, if you have: Failed to include all of the income you earned from any source in the world in your Canadian tax return (including income earned from a foreign bank account or non-Canadian business);failed to file one or more information forms (for example, a T1135 which is required to be filed annually when you have foreign assets exceeding $100,000);failed to file a GST/HST return, orfailed to file a tax return. Publications & Presentations Section Content 3"Take Advantage of the Existing Voluntary Disclosure Program While You Can!," July 24 2017. "The 'Panama Papers': What do they mean for you?," May 2016."New Bank of Israel Directive is Prompting Canadian Taxpayers to Bring Their Tax Affairs in Order," May 21 2015. “Navigating the CRA's Voluntary Disclosures Program,” Toronto Region Board of Trade, On Board Magazine, winter 2014.“A Clean Slate,” Step Journal, April 2014.“Canada Revenue Agency’s Voluntary Disclosures Programme,” International Law Office’s Corporate Tax Newsletter, May 16 2014. Representative Work Section Content 4Borden Ladner Gervais LLP has completed voluntary disclosures for a wide range of matters including disclosures of:Inheritances maintained in offshore accounts;Offshore and Canadian business income;Insurance proceeds maintained in offshore accounts;Unreported employment income;Unreported fees from services rendered;Unreported income from rental properties;Unreported employee benefits income;Failure to withhold and remit payroll taxes;Failure to file T1135 and GST/HST forms; andFailure to withhold 15% Regulation 105 withholding tax on services performed in Canada by non-residents.