On October 19, 2015, Justice Pizzitelli issued his ruling in the long awaited GLGI test case of Mariano v. 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.