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28 www.canadianlawyermag.com LEGAL REPORT TAX In the Coinsquare case, the CRA also obtained external key addresses, says Geneviève Favreau, an associate in McCarthy's tax group. "This is huge," she says, because, with these keys, the CRA can track these users' other crypto transactions on the blockchain. "We saw CRA showing their teeth … in this Coinbase decision." The CRA has also been sending around questionnaires, asking detailed questions about crypto holdings, and now have "action- able information" on crypto-holders, says Cloutier. "It's really something that is top of mind for them." Coincidentally, while CRA is looking harder at crypto, they also recently "narrowed significantly" the voluntary disclosure program, he says. The program used to allow taxpayers to correspond anonymously with the CRA to disclose previously non-disclosed income, pay taxes owing, avoid prosecution and, in some situations, also get a break on the interest and tax owed. The program is no longer anonymous and has become more limited in the relief offered to taxpayers. "That program becoming more stringent – more difficult – around the same time as crypto was becoming audited may have put some people invested in crypto, who have not complied with their tax obligations, in a diffi- cult spot, especially compared to other asset classes." Because crypto transactions are transpar- "Cash is the ultimate refuge for tax evaders. And crypto is the ultimate problem. Forever, you'll be found" Nicolas Cloutier, McCarthy Tétrault Canadian LAW AWARDS 2022 CONGRATULATIONS TO THE 2022 WINNERS AND EXCELLENCE AWARDEES Despite an unprecedented year, legal professionals have continued to raise the bar in terms of service, innovation, professionalism and leadership. And nowhere is this more evident than in the Canadian Law Awards winners and excellence awardees. Lexpert, supporting publications Canadian Lawyer and InHouse and publisher Key Media extend warm congratulations to them all. Special thanks to the external Advisory Panel, comprised of 68 esteemed private practice and in-house counsel leaders, who dedicated their time to selecting and awarding excellence. The winners and excellence awardees will be profiled in Lexpert Special Edition issue 23.03 out in October, which will take an in-depth look at their achievements. For the full list of award recipients and the advisory panellists, visit THURSDAY, MAY 19, 2022 • ARCADIAN COURT TORONTO OFFICIAL MEDIA SUPPORTING MEDIA ORGANIZER PHOTO BOOTH SPONSOR SUPPORTING ORGANIZATIONS W O M E N G E N E R A L C O U N S E L C A N A D A OFFICIAL BALLOT ACCOUNTANTS www.lawawards.ca #LawAwardsCA AWARD SPONSORS