Walls – Tax Court of Canada finds that a savvy home developer “knowingly” failed to report his substantial profits

A licensed real estate agent, who had been reporting income of about $20K a year, realized gains from the construction and sale (in 2006, 2008 and 2010) of three homes in Vancouver (together with a small gain from the sale of a vacant lot) totaling over $2.2 M. He professed to have constructed each home as a principal residence, but did not substantiate that he or his family occupied the homes.

Visser J affirmed the gross negligence penalties assessed on the taxpayer for his failure to report his business profits on the basis that the taxpayer “knowingly made false statements or omissions in his 2006, 2008 and 2010 tax returns.”

Neal Armstrong. Summary of Wall v. The Queen, 2019 TCC 168 under s. 163(2).