Publications

Fines and Penalties

Section 67.6: “In computing income, no deduction shall be made in respect of any amount that is a fine or penalty (other than a prescribed…

Hine v The Queen: settlement offers in “yes-no” cases

In Hine v The Queen (2012 TCC 295), the application of the gross negligence penalty for the 2006 taxation year was the sole tax issue…

Foreign Reporting Penalties

The May 21st edition of the National Post featured an article by Jamie Golombek discussing the harshness of the penalties for late-failing a T1135 Foreign Income Verification Statement;…