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Opportunities for the Disabled Foundation v. Canada (National Revenue) 2016 FCA 94 (Ryer, Near, Boivin, JJ.A.) — returns must be complete to be valid but minor inaccuracies are OK

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The reasons in this decision suggest that the appellant’s arguments were generally misconceived.  Still, the case gave the Court the chance to make this statement that can be relevant to all information returns required by tax laws.  I.e., the comment need not only apply to the T3010 returns that registered charities must file:  

​[48]           I reject the Appellant’s narrow interpretation of paragraph 168(1)(c). 
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Filing an information return “as required” by the Act or a regulation must entail filing a return that corresponds with the requirements for a return set out in the Act and in applicable regulations. The Appellant’s submission essentially reads down paragraph 168(1)(c) to eliminate the word “as.”

[49]           On the other hand,
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 I do not wish to be taken as having concluded that any minor inaccuracy in a T3010 will justify a Ministerial decision to issue a notice of intention to revoke the registration of a registered charity.

[50]           In the circumstances, I am satisfied that the record amply demonstrates that the inaccuracies in the T3010 cited by the Minister in the Administrative Fairness Agreement are well beyond what might reasonably be viewed as minor. 

Opportunities for the Disabled Foundation v. Canada (National Revenue) 2016 FCA 94 (Ryer, Near, Boivin, JJ.A.) 

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