The Supreme Court of Canada released its anticipated decision in Guindon v. Canada on July 31, 2015, which held that administrative monetary penalties (“AMPs”) under section 163.2 of the Income Tax Act (the “ITA”) are not offences that trigger constitutional protections such as the right to be presumed innocent. Other…
Mark Tonkovich is an associate in the Toronto office’s Tax Practice Group of Baker & McKenzie. Prior to joining Baker & McKenzie, he completed a judicial clerkship at the Federal Court of Appeal and was a tax litigator with the Canadian Department of Justice. Although he is experienced on both sides of the courtroom, he also frequently resolves tax controversies without the need for formal litigation.