due diligence

Filiatrault c. La Reine, 2017 TCC 232 (Informal Procedure) -- summary under Subsection 280(1)

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due diligence defence to the imposition of interest is available

CRA had assessed the taxpayer for interest under ETA s. 280 for his failure to file returns for what had now been found by Smith J to be a taxable...

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Chiang v. The Queen, 2017 TCC 165 (Informal Procedure) -- summary under Subsection 162(1)

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Chiang v. The Queen, 2017 TCC 165 (Informal Procedure)
no penalty where reasonable error of fact

The taxpayer made contributions to his RRSP for the years 1995 to 2005 (except 1998). In preparing his 1995 and 1999 returns, he reported his...

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Ogden Palladium Services (Canada) Inc. v. The Queen, 2001 DTC 345 (TCC), briefly aff'd 2002 DTC 7378, 2002 FCA 336 -- summary under Paragraph 227(8)(a)

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Ogden Palladium Services (Canada) Inc. v. The Queen, 2001 DTC 345 (TCC), briefly aff'd 2002 DTC 7378, 2002 FCA 336
due diligence defence not established in absence of evidence of professional advice

Before finding that a due diligence defence had not been made out respecting the imposition of a 10% penalty under s. 227(8)(a) respecting failure...

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Résidences Majeau Inc. v. Canada, 2010 FCA 28 -- summary under Section 285

components of due diligence defence

Majeau built an addition on one of its properties for a total cost of $1,295,688, but calculated its GST owing on the basis that the FMV of the...

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