What is the impact of a penalty for failing to properly assess the risk to a taxpayer in a property transaction?

Canada (Federal), Canada

The following excerpt is from Thompson v. The Queen, 2010 TCC 381 (CanLII):

Justice Boyle in Dunlop v. The Queen, 2009 TCC 177, 2009 D.T.C. 650, [2009] 6 C.T.C. 2223 reiterated that the penalty will not apply if the taxpayer “can demonstrate he exercised a requisite degree of due diligence”.

Other Questions


What is the penalty for failing to prove each of the grounds in a termination letter? (Canada (Federal), Canada)
In what circumstances will a municipality be liable for failing to properly inspect the foundations of residential premises? (Canada (Federal), Canada)
Can a vendor in a real estate transaction repudiate the contract by failing to convey title in fee simple? (Canada (Federal), Canada)
What is the impact of a visa officer's failure to consider the applicant's property holdings and valuations? (Canada (Federal), Canada)
What is the quantum of a penalty for failing to comply with an administrative or regulatory scheme? (Canada (Federal), Canada)
Is a Minister's duty to assess a taxpayer's income tax returns mandatory or discretionary? (Canada (Federal), Canada)
Is a debtor who transfers property to a non-arms’ length third party who has transferred property subject to the debtor’s subsequent bankruptcy? (Canada (Federal), Canada)
Can a property acquired through reinvestment of a gift or legacy exempt from seizure even without a stipulation of unseizability regarding that property in the deed of gift or in the will? (Canada (Federal), Canada)
Is allocation of shareholder benefits to a taxpayer’s shareholder justifiable where that benefitting taxpayer is a shareholder? (Canada (Federal), Canada)
What is the test for the calculation of an allowance under the Income Tax Arrears for the purchase and use of property acquired through a property purchase scheme? (Canada (Federal), Canada)

There are no other similar questions at this time.