On October
19, 2015, Justice Pizzitelli issued his ruling in the long awaited GLGI test
case of Marianov. Her Majesty the Queen. As I wrote about in a previous blog, the outcome was the worst case
scenario for clients of GLGI. Justice
Pizzitelli’s stinging rebuke of the GLGI program is captured in his case
conclusion as follows:
“Having
regard to all the foregoing, I find that the Appellants did not have the
donative intent to make any of their gifts, did not own or transfer the
property that is the subject matter of the gift in kind, i.e. the Licences, and
that the Program was a sham;
..…..Accordingly, the appeals are dismissed, with costs to the Respondent.”
There you
have it. GLGI was found to be a sham,
therefore no portion of your donation – not even the initial cash outlay – will
be allowed. A complete victory for the
Canada Revenue Agency (CRA).
Those of
you who took my earlier advice and signed the CRA’s offer of
settlement prior to this decision can consider yourselves extremely lucky. Not only did you get the cash portion of your
donation allowed, you also received thousands of dollars in immediate interest
relief!
GLGI has
until November 19, 2015 to file an Appeal to the Federal Court of Canada. Frankly, given the clear and complete victory
by the CRA in the Tax Court of Canada case last week, an Appeal, in my opinion,
would be unlikely to succeed. The
reality is that the large tax debts owed by GLGI clients are not going away and
legal action by the CRA looms larger and larger by the day.
What can
you do? Give our team of tax specialists - which include former senior CRA
staff – a call right away. We will stand
between you and the CRA to protect you from legal action while we negotiate a
fair repayment plan based on your ability to pay. We can also discuss how we can get reduce
your CRA debt by thousands of dollars through a reduction in interest
charges.
Call
now! We offer a free, no risk
consultation where we will discuss your individual circumstances and outline
the best options available to assist you. 1-888-868-1400.
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