CRA was not unreasonable in not recommending remission where taxpayers realized stock option benefits on stock that became worthless
The taxpayers realized stock option benefits, and then the stock became worthless somewhat later without their having exercised. In finding that it was not unreasonable of the CRA to conclude that no remission of the tax, interest and penalties should be recommended, Southcott J noted the CRA findings that the taxpayers had sufficient home equity to pay the liabilities, and “that the potential for a sudden decline in value after acquiring shares is a known risk” - and then further indicated that “it was within [CRA’s] discretion to be influenced significantly by the public interest in collection of taxes.”
Neal Armstrong. Summary of Anderton v. Canada (Attorney General), 2021 FC 788 under Financial Administration Act, s. 23(2).