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Toronto." The downside to establish- ing an offshore trust is the time and cost involved as well as the scale — "it's probably not cost-effective for less than a half a million, probably a million." He advises his clients to have an amount of money necessary to cover at least six months' worth of expenses. Secrecy is not a prime motivator for such clients, while asset protection from creditors, business partners, or even spouses is. While owning offshore trusts could subject individuals to heightened scrutiny by the CRA, there is nothing illegal about setting up and holding an offshore trust, provided that any income is reported to the tax authorities. The three-sided international efforts to rip away the veil of secrecy of OFCs, through government-to-government pressure, government-to-institution pressure, and with the rise of whistle- blowers will be an ongoing concern for the unknown numbers of Canadians that have long-standing and undeclared off- shore accounts, says David Lesperance, whose boutique law firm Lesperance & Associates specializes in citizenship, residence, and domicile strategies for the wealthy. "Illegal options [are] no longer available to them," he says. A combination of rising govern- ment debts and an increasingly mobile, wealthy international cohort of "golden geese" in Lesperance's parlance should translate into heightened competition for wealthy citizens willing to relocate for tax relief. "When we look at off- shore financial centres . . . their busi- ness model, if it was based on secrecy, is kind of blown out of the water. There are already governments gearing up" to attract this well-heeled international group "on a legal, full-disclosure basis." Lesperance notes that the term "off- shore financial centre" can be expanded to include any country other than the one an individual is currently residing in, even Canada. To that end, in June he is presenting a white paper in London, England, organized by the Canadian High Commission and the Canada-U.K. Chamber of Commerce to U.K.-based hedge-fund managers looking for low- tax jurisdictions. While thought of as a high-tax juris- ntitled-7 1 Carol Denman, co-founder Thanks to you, it's been a great ride! This year, Atchison & Denman turns 25. Thanks to our loyal clients for helping us to be among the "fi rst in fl ight" on so many fronts, such as e-Transcript and Real-time Transcription. ... and for your commitment to quality evidence, gathered using our in-house discovery facilities; and reported using our network of professional court reporters across Canada. As your legal services partner, we look forward to the next 25 years! Atchison & Denman 155 University Ave., Suite 302, Toronto, Ontario Toll free: 800.250.9059 Toronto: 416.865.9339 stenographers.com www. C ANADIAN Law ye rmag.com JUNE 2010 35 5/17/10 10:36:33 AM diction, Canada qualifies as a tax haven internationally. Ottawa allows newcom- ers to set up a five-year immigrant trust which is tax-free for that span. "I have been giving effectively this presentation my entire legal career," he says. "But now the drivers are there and now in particu- lar people are leaving the U.K. and the next round will be in the United States." After 20 years in his golden geese "micro niche," Lesperance finds himself with just a few, mainly Europe-based, competitors. It's a situation that is unlikely to last, although he believes there is going to be plenty of business to go around as the world's well-to-do geese seek new nests to safeguard their eggs. "The Canadian firms can do very well by realizing, 'Hey, here is some- thing that is our area of expertise and we are going to sell it to the world,'" he says.