CRA auditors regularly assess gross negligence penalties. The concept of gross negligence is discussed from a historical perspective and in relation to 2014 CRA audit policies. The paper further discusses negligence in tax law, and the standard of care required by taxpayers when preparing and filing their tax returns and the onus of proof the CRA must meet when assessing gross negligence penalties.
The articles on this website reflect the authors understanding of the law at the time the article was written. The rules in tax law change regularly and the enclosed articles should be read for information purposes only. They do not necessarily represent the current state of the law. The Law must be applied to a particular set of facts. It is unsafe to draw conclusions about a particular set of facts without having them reviewed by a specialist.