RE:RE:RE:CRA decision? Globe says Silver Wheaton disputes CRA assessment
2016-10-05 08:24 ET - In the News
The Globe and Mail reports in its Wednesday, Oct. 5, edition that Silver Wheaton is locked in a battle with the Canada Revenue Agency. The Globe's Ian McGugan writes that Silver Wheaton is a so-called streamer. It provides upfront cash to miners in exchange for the continuing right to purchase a portion, or stream, of their future output at discounted prices. The bulk of Silver Wheaton's streams comes from mines outside of Canada. The silver and gold produced by those mines are sold through a Silver Wheaton subsidiary in the lightly taxed Cayman Islands. The CRA objects to this arrangement and argues that the profit should properly be taxed in Canada. It has presented Silver Wheaton with a reassessment notice that demands $353-million for the years 2005 to 2010. For its part, Silver Wheaton says the tax agency is overstepping its mandate by trying to tax transactions involving metal that was produced outside of Canada and sold outside of Canada, without ever touching Canadian soil. The company is appealing the CRA assessment in the Tax Court of Canada and says it is confident of victory. Silver Wheaton hopes to arrive at a settlement when the discovery process begins.