In Semenov v R, 2018 TCC 58, the CRA found unexplained deposits in the individual taxpayer’s personal bank account. The CRA applied a “deeming” rule to treat the amounts as unreported income subject to gross negligence penalties. The CRA applied…
Fiscal Arbitrators update
Carolyn Hogan, “Escaping Penalties After Admitting False Statements” 6:3 Canadian Tax Focus (August 2016) is a good snapshot of the state of play in the ongoing Fiscal Arbitrators fiasco.
Onus and penalties
SCC dismisses Guindon appeal
The Supreme Court has dismissed the taxpayer’s appeal in Guindon v R, 2015 SCC 41.