At https://www.mondaq.com/canada/income-tax/833802/gordon-et-al-v-the-queen-canadian-tax-lawyer39s-analysis-and-comments
are comments on a court case decided last year, which was fought over the issue
of whether a CRA Investigation into an SRED practitioner’s routine of creating
back-dated documents to make it appear that transactions and circumstances had
occurred when they had not. The court’s findings make sense to me, with the
exception of the determination that government reports labeling one of the
individuals connected with the plaintiff as a “troublemaker” were not damaging
to the subject’s name. The reason given by the Court to support the finding that
the individual’s reputation was not damaged by the remarks is that such labeling practices are common within government! So, holding up a convenience
store (easier now that masks are routinely worn) is alright because hold-ups
are common? Yikes! It is a sad state into which a Just-Us system has fallen
when such reasoning passes scrutiny.
It is interesting though that the Court seems to have acknowledged
that where poorly documented transactions or relationships had existed, it is a
satisfactory accounting tactic to post
hoc create missing documentary evidence.
