(available in print only version)
“The CRA adopted more dissuasive penalties, explains François Barette, a partner with the Fasken Martineau’s Taxation group, because they affect promoters and consultants as well as taxpayers. For its part, Revenu Québec (RQ) imposes a penalty on the taxpayer. However, if it’s proven that there was an aggressive tax planning scheme involved, the General Anti-Avoidance Rule then applies, which imposes a penalty on the promoter”.