Here is an interesting Federal Court case McNally v. Canada (National Revenue) 2015 FC 767 dealing with a delay by CRA in issuing a notice of assessment when a taxpayer has participated in what CRA would an abusive charity gifting tax scheme. Apparently the case is being appealed to the FCA.
Here is a link to McNally v. Canada (National Revenue).
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Mark Blumberg is a partner at the law firm of Blumberg Segal LLP in Toronto and works almost exclusively in the areas of non-profit and charity law.