Conrad Black owes the Canadian government taxes on $5.1 million of income and taxable benefits from 2002, according to a ruling by the Tax Court of Canada.
Chief Justice Gerald Rip sided with the Canada Revenue Agency’s argument in a dispute over Black’s residency status because he owned homes in both Canada and the United Kingdom.
“As a resident of Canada, he is subject to tax on his worldwide income, including from employment in a third state,” Rip wrote in his Jan. 14 ruling.
“Therefore, I determine that the Minister of National Revenue may assess tax against the applicant.”
Black’s lawyers had argued that he was a resident of the United Kingdom at the time and not subject to Canadian tax rules.
Black renounced his Canadian citizenship in 2001 so that he could become a British Lord. He became a resident of the United Kingdom in 1992, and remained a resident throughout 2002, court papers said, but while he was a resident of the U.K., he wasn’t actually living there at the time in question.
The statement of facts filed with the court also said that Black has already paid Canadian taxes on $808,226 of domestic work when he was not a resident of the country.
The CRA’s bill, however, includes tax on an additional $2.9 million in income earned for work done outside of Canada and $1.4 million for benefits from Black’s use of an airplane Hollinger International Inc. had access to.
It also includes tax on $90,000 worth of security for his Toronto home and $365,500 the agency claims Black recognized from the debts of Conrad Black Capital Corp.
Black has been living in Toronto since 2012, when he finished serving 37 months in the U.S. for convictions on fraud and obstruction of justice. An appeal court tossed out two other fraud convictions against him and two other Hollinger executives.
He has been steadfast in declaring his innocence on all charges and in his belief that he was subjected to unfair prosecution in the United States.
Most recently, he asked the Ontario Securities Commission to stay or at least limit the scope of regulatory proceedings against him in Canada, because he says those cover many of the questions already dealt with by the court in Chicago and through a settlement reached with the U.S. Securities and Exchange Commission. That agreement, announced in August, bars Black from acting as a director of a public company in the United States.
The OSC proceedings seek to deal with the fallout from a complicated system of non-compete payments involving Hollinger Inc. and Hollinger. Black’s motion will be heard on March 26.
Black did not immediately respond to a request for comment Tuesday, and the CRA does not comment on tax cases due to confidentiality laws.
CORRECTION: An earlier version of this story incorrectly stated that Conrad Black owed $5.1 million in taxes.