•Guindon v.
The Queen, 2012 TCC 287
–The case dealt with third party penalties provided under section 163.2 of the ITA
–The basic purpose of s. 163.2 is to provide for monetary penalties assessable against third parties who, participate in, promote, or assist conduct that results in another taxpayer making a false statement or omission in a tax return
–Court concluded that the penalties under s. 163.2 are criminal in nature meant that the penalties would therefore have to be prosecuted not in a tax court