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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 »

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 »

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 »

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 »