In finding that CRA could not reassess beyond the normal reassessment period to include substantial amounts as alleged unreported shareholder benefits from non-resident corporations in the income of the taxpayer (Mr. Goldhar) for his 2008 to 2011 taxation years, Visser J stated (at para. 46):
Mr. Goldhar carried on an international business, and engaged professional lawyers and accountants to assist in organizing his financial affairs and in filing his personal and corporate tax returns. … Considering the complexity of Mr. Goldhar’s businesses and his lack of tax expertise, it is my view that he took all reasonable steps that a wise and prudent person would to ensure that his tax returns were filed properly during the taxation years under appeal. … Mr. Goldhar lacked the expertise to undertake a more thorough review. He would have had to be a tax expert to do so. That is not the standard. That is why he engaged a professional accounting firm, which had professional tax experts within its ranks, to provide him with tax advice and file his tax returns.