On February 28, 2015, the Government of Canada announced in the Canada Gazette that it would begin enhanced information sharing between Citizenship and Immigration Canada (“CIC”) and the Canada Revenue Agency (“CRA“). To many representatives who have been stunned at how many people can seemingly get away with reporting different information to the two government departments this is welcome news.
As the Government of Canada noted in the Gazette:
There is currently no authority under the Citizenship Act or the Citizenship Regulations (the Regulations) to enable CIC to collect the [Social Insurance Number (“SIN“)] for the purposes of exchanging information with the CRA. As a result, for verification of residence, CIC is currently using the CRA notices of assessment, a process that is known to be vulnerable to fraud, is less reliable, and is an inefficient use of the CRA and CIC resources.
Amendments to the Immigration and Refugee Protection Regulations (“IRPR“) will authorize CIC to collect the SIN and to verify information with the CRA. As well:
In reviewing the tax filing history of citizenship applicants, CIC may encounter inconsistent or contradictory information that may raise tax compliance concerns; however, CIC does not currently have the express authority to proactively advise the CRA of these types of concerns to improve the integrity of its programs. The proposed Regulations would address this issue.
After the amendments, IRPR will state:
26.3 The Minister may disclose information with respect to the citizenship status of a person to any department or agency of the Government of Canada or of a province with which the Minister has entered into an arrangement or agreement for the disclosure of this information for the purpose of determining the person’s eligibility for a benefit or program.
26.6 (1) The Minister may require an applicant to provide their social insurance number, if any, in any application made pursuant to subsections 5(1) or 11(1) of the Act.
(2) The Minister may disclose the following information to the Canada Revenue Agency if the Minister has entered into an arrangement for the disclosure of this information:
(a) the social insurance number of an applicant for the purposes of verifying whether the applicant has complied with the requirements set out in paragraphs 5(1)(c), 5(1.2)(b), 11(1)(d) and 11(1.1)(b) of the Act; and
(b) any relevant information related to any discrepancies between the information obtained from the applicant and that provided by the Agency if there are reasonable grounds to believe that the discrepancy is a result of false representation, fraud or concealment of material circumstances made in the course of an application, as well as any personal information, including the social insurance number, of an applicant that the Agency is authorized to collect for the purpose of the administration of its programs and the enforcement of the legislation for which it is responsible.