The secret world of corporate tax avoidance [Toronto Globe and Mail (Ontario, Canada)]
Bank Of Montreal (BMO)
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Source: Toronto Globe and Mail
Allan Lanthier is a former chair of the Canadian Tax Foundation, and a retired partner of Ernst & Young. Are large Canadian corporations bilking us out of billions of tax dollars every year, as commentators sometimes suggest? And if so, how do they get away with it? Two recent decisions of the Tax Court of Canada offer some answers, and a rare glimpse into the secretive world of corporate tax avoidance. The first decision involves Bank of Montreal. In 2005, Harris Bank – BMO’s wholly owned U.S. subsidiary – required cash, and third parties were willing to lend the funds. You might have thought that Harris would simply borrow the cash from the third parties. You would have been wrong. Story continues below advertisement Instead, BMO established a complex finance vehicle referred to in tax circles as a “tower structure. The structure typically involves three entities – a U.S. limited partnership, and a corporation in each of Nova Scotia and D
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