The OBA office will be closed from December 24 to January 2 for the holidays and will resume normal operations on January 5.

Skip to main content

The Collateral Consequences of a CRA Criminal Investigation: What Taxpayers and their Advisors Should Know

June 4, 2025 | Brian Studniberg & Taylor Wormington, Henein Hutchison Robitaille LLP

Introduction

Taxation law is a complicated, nuanced beast. When a criminal investigation is launched by the Canada Revenue Agency (CRA) into a taxpayer for alleged violations of tax law, the law’s complications become more pronounced. In these moments, it can be stressful for taxpayers and their advisors to be aware of certain collateral consequences that can arise from criminal investigations. That said, it is frequently worse for the taxpayer to overlook the ways in which a criminal tax investigation presents a different set of challenges than regular tax administration.

This article aims to introduce taxpayers and their advisors to some of these collateral consequences, including: Disclosure of taxation offences and investigations to the public; invasive and lengthy investigations conducted by the CRA; and the possibility of charges being laid against individuals associated with the taxpayer. When advising taxpayers on their tax liability in situations where there is potential for criminal charges, it is important to be mindful of these consequences derived from criminal law.

Please login to access this article.

Login to MyCBA