A recent decision from the Ontario Court of Justice suggests that extraordinary circumstances are required in order for a defendant to be compelled to produce financial documents to the Crown for the purposes of a sentencing hearing.
Close to one million American expatriates and dual citizens live in Canada, many of whom haven’t worked, lived, or even stepped foot in the U.S. for years. Many of them don’t report their income to the IRS, mistakenly believing that they don’t have to because they don’t owe the IRS any taxes. But as of July 1, 2014, the CRA will begin collecting and sharing with the IRS information on any “U.S. person” with accounts in a Canadian financial institution.