CRA has provided information through ATIP on third-party civil penalties from 2009 to 2016. The number of completed third-party penalty audits where it was determined that the penalty would be applied is 67. The amount of the penalties was about $164 million. Here is the disclosure.
Here is information on third-party civil penalties on the CRA website.
One can expect an increase in the number of third party civil penalties after the Guindon case.
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