Précis: Ms. Guindon was a lawyer who had issued an opinion which was used to market a charitable leveraged donation program; she was also an officer of the charity involved and signed the tax receipts that were issued totalling $ 3,972,775. She was assessed advisor penalties totalling $546,747 pursuant to subsection 163.2 (4) of the Income Tax Act (the “Act”), the so-called “preparer penalty”.
Guindon v. R - SCC: Tax preparer penalties survive a Charter-based challengePlus >