Posts filed under: Canadian Tax Penalties
Federal Court of Appeal Overturns Guindon Decision of Tax Court of Canada
We previously wrote about the Tax Court of Canada decision released on October 2, 2012, Guindon v. R., 2012 TCC 287 (“Guindon”). The Guindon decision had dramatic implications for any Canadians who were assessed third party penalties pursuant to section 163.2 of the Income Tax Act (the “Tax Act”). The decision… more »
About Pushor Mitchell Tax Group
When disputes arise we have considerable experience in dealing with the Canada Revenue Agency and in representing clients in income tax and GST appeals. more »
Tax Court of Canada Finds That Third Party Penalties Are Criminal Sanctions
On October 2, 2012 the Tax Court of Canada released its decision in Guindon v. R., 2012 TCC 287 (“Guindon”). This decision has dramatic implications for any Canadians who have been assessed third party penalties pursuant to section 163.2 of the Income Tax Act (the “Tax Act”). If you have… more »
About Pushor Mitchell Tax Group
When disputes arise we have considerable experience in dealing with the Canada Revenue Agency and in representing clients in income tax and GST appeals. more »
The Problem with Penalties
The Canada Revenue Agency seems more and more willing to impose penalties for all sorts of perceived transgressions. We've talked about penalties in a previous blog post ( https://www.taxdisputehelp.ca/2011/10/fighting-the-imposition-of-gross-negligence-penalties ). One that seems to be a trap for the unwary and can be very unfair is the penalty for… more »
About Thomas Fellhauer
Tom’s practice includes a wide range of tax law matters including tax planning, company law, corporate reorganizations, trusts, estate planning and succession planning for family businesses for clients. more »
Fighting the Imposition of Gross Negligence Penalties
The Canada Revenue Agency can impose gross negligence penalties in addition to the assessment of tax. Gross negligence penalties are imposed under subsection 163(2) of the Income Tax Act. Under the Income Tax Act gross negligence penalties are determined with reference to the amount of tax owing: gross negligence penalties are 50% of… more »
About Pushor Mitchell Tax Group
When disputes arise we have considerable experience in dealing with the Canada Revenue Agency and in representing clients in income tax and GST appeals. more »