While donors to fraudulent donation schemes may not be morally innocent, their culpability does not reach the level of the promoters of these schemes. It is refreshing to see the CRA prosecuting those responsible, rather than merely reassessing and penalizing taxpayers.
In a report entitled "Donor Beware" the Tax Ombudsman opined on the CRA's administrative responsibilities regarding charitable donation tax shelters. Perhaps the most surprising thing about the report is that it is dated March 19th, 2014, after years of legislative implementation of tools for the CRA to crack down on tax shelter promoters, charities, directors of charities and donors connected with such plans. As far as we can tell most offensive tax shelters seem to be shut down albeit leaving several large messes still to be cleaned up.