On Monday July 6th, Silver Wheaton Corp. (NYSE/SLW) received a proposal letter from the Canada Revenue Agency (CRA), in which the tax authority is proposing to reassess the company under various rules in the country’s tax code. (Source: Silver Wheaton Corp, July 6, 2015.)
The CRA’s proposal says Silver Wheaton’s taxable income from 2005 to 2010 should be increased by approximately CDN$715 million (USD$567 million). On a preliminary basis, Silver Wheaton estimates that for the CRA’s Relevant Taxation Years, the company would be subject to federal and provincial taxes of approximately $150 million. The CRA is also seeking to apply CDN$72.0 million (USD$57.0 million) of transfer pricing penalties.
According to the press release, Silver Wheaton’s management believes that their filings and tax payments are in compliance with Canadian tax law. The company is preparing its response to the CRA’s proposal and plans to “vigorously defend” its tax filing positions.
If Silver Wheaton Corp. fails to defend its tax filing positions, the company would have to pay the full amount of the reassessed tax, interest, and penalties. This would have a substantially adverse impact on the company’s financial results.
Following the news, Silver Wheaton’s stock price plunged 11.9%, closing at $15.46 on Tuesday July 7th.
As a result of the CRA’s proposal, several law firms have begun investigating potential securities claims on behalf of investors of Silver Wheaton Corp. Among them were Pomerantz LLP, The Rosen Law Firm, and Bronstein, Gewirtz & Grossman LLC. According to Pomerantz LLP, the investigation concerns whether Silver Wheaton Corp. has violated securities regulations.