IC01-1R2 Third-Party Penalties 17 February 2026 [IC 01-1R2]

Conventional tax-planning techniques carried out for a fee generally are not excluded activities

53. Generally, the use of rollover provisions,...

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General background to ss. 163.2(2) and (4)

Before the third-party penalties took effect on June 29, 2000, there were no administrative penalty...

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Use of subordinate definition

27. To determine if the particular person participated in the making of a false statement, it may be necessary to...

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Meaning of key adjectives

Tantamount to intentional conduct

31. The expression tantamount to intentional conduct in the definition of culpable...

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Availability of good faith exception

45. … The good faith reliance exception is available when the information is provided to the advisor by or...

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S. 163(2) penalty is used only as a quantitative measure in the s. 163.2(5) calculation

83. For this calculation, it is important to note that the...

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Avoidance of double-counting

91. Paragraph (12)(b) ensures that each planner penalty assessed against a person for the same planning activity or...

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Basic distinction between s. 163.2(2) and (4)

11. The planner penalty is directed primarily at any person who generally prepares, participates in...

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