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The court struck parts of Mr. Schmeichel’s tax appeal that lacked a clear inventory-adjustment basis, but allowed him to file an amended notice by June 26, 2026.
Judicial review allowed where the Federal Court found the CRA’s taxpayer-relief decision under s. 220(3.1) of the Income Tax Act was unreasonable.
The Tax Court dismissed Eric Aidoo’s appeal over GLGI-related charitable donation claims for the 2007 taxation year, finding no donative intent and rejecting ancillary arguments.
Applying Mariano and settled law, the Court found the appellants objectively lacked donative intent because they expected to be enriched by tax benefits, did not own or could not identify the licences donated, the Trust failed for lack of certainty and proper trustee exercise, and the licences' fair market value was nominal; therefore the claimed charitable deductions were not eligible and the appeals are dismissed.
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The undertaking given in discovery was to produce all documents in the Minister’s possession that pertain to the decision to allow the gifts in the first instance; the Respondent had narrowed that undertaking in its response and therefore must conduct a further review and produce all documents pertaining to that decision (subject to privilege) by December 22, 2022; costs of the motion are awarded to the Appellant but there is no award of exemplary or solicitor-client costs and no award of costs for the discovery process to date.
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The Federal Court of Appeal dismissed the appeal because the Tax Court’s refusal to accept the full amount of the claimed cash payments was a defensible factual finding supported by the record (poor records, inconsistencies, lack of corroboration); absent a palpable and overriding error, the appellate court will not substitute its own view of the evidence.
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The Minister proved on a balance of probabilities that the appellant claimed charitable tax credits he did not make and was negligent in failing to verify his tax returns; accordingly reassessments for 2003 and 2004 were valid under s.152(4)(a)(i), the charitable credits for 2003, 2004 and 2007 were properly disallowed, and penalties under s.163(2) were properly imposed because the appellant's conduct amounted to gross negligence/wilful blindness; appeal dismissed.
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The Tribunal, being satisfied with the reasons and information provided and exercising its discretion under s.74.13(b) of the Competition Act, allowed the consented variation to paragraph 3 of the Consent Agreement to reallocate the 2020 donation to specified hospitals and charities (including cash and in-kind PPE) and otherwise left the Consent Agreement unchanged; no costs were awarded.
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On the evidence the appellant failed to discharge his burden to rebut the Minister’s assumptions that he lacked donative intent and therefore the 2008 reassessment disallowing the $65,000 donation is upheld; however the Crown failed to prove the facts required to justify the late imposition of a gross-negligence penalty under s.163(2) and/or the reopening under s.152(4)(a)(i), so the 2009 reassessment (penalty) is vacated and the penalty is removed.
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All Type I appeals were dismissed because appellants failed to produce the mandatory 2010 charitable donation receipts required by s.118.1(2) of the Income Tax Act and, in several cases, failed to appear or comply with court-ordered case management deadlines, permitting dismissal under the Rules.
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