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Cannon v. Parklane Financial Group. disallowing the tax credits for participation the Donations for Canada Gift Program. ParkLane offered a charitable tax. Nova Scotians settle class action. endorsing ParkLane Financial Group Ltd.’s Donations for Canada. ParkLane allegedly offered the program as a charitable.
Certification Granted In Charitable Donation Tax "Scheme" Class Action - Litigation, Mediation & Arbitration. If it walks like a duck, quacks like a duck, looks like a duck. Or, as observed by Justice Strathy in a class action certification and. Wednesday. when representative plaintiff Michael Cannon thought that the tax.
Donations Canada Gift Program which. Just south of 1. 0,0. Canadian taxpayers from every province and. Gift Program. between 2. However, in the eyes of the. Canadian Revenue Agency (C.
R. A.) which reassessed and distributed. Gift Program was nothing. Mr. Cannon brought a motion for. Background. The Gift Program, described by Justice Strathy as the. Edward Furtak. who developed a computer software program which supposedly had a.
Bermuda Trust which was. Mr. Furtak for the benefit of himself and his family. The software program was then licensed by the. Bermuda Trust to a Bermuda company also owned by Mr.
Furtak called. Trafalgar Trading Limited (TTL). When the taxpayers made donations. Bermuda trust would temporarily inject funds which flowed. TTL for the use of the software program.
This. "super- sizing", noted Justice Strathy, "made the. How to Bake a Gift Program. The recipe for the Gift Program involved 6 ingredients, a 7 step. The list of ingredients, as compiled by Justice Strathy.
Registered Canadian Amateur Athletic. Associations that were in need of cash and were prepared to give. Mr. Furtak's companies.
Gift. Program could likely sustain a challenge by the C. R. A.; (5) a sales. Gift Program to potential donors (the. Independent Financial Advisors" or. Distributors"); and (6) cash to inflate the donors'.
C. R. A. that real money was. Justice Strathy went on to set out the 7 steps which occurred. The donor would write a cheque. At the same. time, the donor would apply to become a beneficiary of the.
Donations Canada Financial Trust (a private charitable trust. Mr. Furtak). An escrow agreement would be executed by. Park. Lane (an Ontario corporation incorporated. Mr. Furtak for the purposes of promoting leveraged charitable. Gift Program, to Canadian. After receiving the.
Donations Canada Financial Trust made. Park. Lane as escrow agent. The donor was given a confirmation of.
The. sub- trust units would then be donated to the charity at which point. The charity. under the terms of its agreement with the Gift Program, was then. The funds for. the redemption were provided by the Bermuda Trust which. Donations Canada Trust".
At this point the charity. Finally, in return for the donor's total donations, he or she. A cash receipt for. C. R. A. took the position that these donations were not a gift. In the absence of a "donative intent" the. The Certification Motion.
The plaintiff asserted multiple causes of action against. The various causes of action included.
Consumer Protection Act. The various defendants included the. Park. Lane Defendants"3, the Funds for Canada. Foundation (FFC Foundation)4 and its directors, the. Gleesons. 5, the lawyers who provided the opinion and. Appleby and the Bermuda Trust. Mr. Furtak was originally a defendant, but the plaintiff settled with.
In assessing whether the pleadings disclosed a cause of action. Class Proceedings Act. Justice Strathy held that the plaintiff had. His. Honour disagreed with the defendants who argued that the claim in. His Honour examined case law where the negligence.
In this case, Justice Strathy found that. Somewhat similarly, some of the defendants submitted that the. Justice Strathy, however, found that the pleading of fraud referred. His Honour agreed with the plaintiff's. With regard to the claim for breach of the Consumer. Protection Act, 2.
Gift. Program was a "consumer transaction" and that the. Gift Program, giving rise to a remedy in rescission or damages. The defendants argued that the legislation is. Act did not include regulation of charitable giving.
Justice Strathy held that "while. Act], the Gift Program itself was far from.
His Honour found that the plaintiff had pleaded a. The remaining elements of the test for certification were met. The common issues certified included breach of contract. Consumer Protection Act. The Summary Judgment Motions. Both Park. Lane and the Lawyers brought motions for summary.
Park. Lane for dismissal of the claim against it. Lawyers for dismissal of the claims for. Park. Lane's argument. Donor Declaration and Tax Risk Disclosure. Statement (part of the contractual materials every donor. Gift Program was required to sign), Mr.
Cannon. accepted the risk of his claim for a tax deduction being refused. Park. Lane from liability. The Lawyers argued. Cannon and therefore. Gift. Program could not succeed. Justice Strathy outlined the test for summary judgment as.
Court of Appeal for Ontario's recent decision in Combined Air Mechanical Services Inc. Flesh and its application of the new. His Honour stated: the new test focuses on procedural.
The Court cautioned that before embarking. Rule 2. 0. 0. 4(2. Can the full appreciation of the evidence.
Both motions for summary judgment were dismissed. His Honour. held that there was a genuine issue requiring a trial about whether. Mr. Cannon and Park. Lane (including the Donor. Declaration and Tax Risk Disclosure Statement relied on by the.
Consumer Protection Act, 2. His Honour observed,on one view of the evidence, the Gift. Program was a bona fide, well- designed plan to minimize. One of those risks unfortunately came to.
On another view of the. Gift Program was a giant shell game and the so- called. Independent Financial Advisors (the "Distributors") were. Ultimately, Justice Strathy concluded: there is indeed a genuine issue. Park. Lane's conduct lies on. These are matters of public interest.
On the Lawyers' motion, Justice Strathy concluded that there. Conclusion. Finding that on the evidence before him the plaintiff had met.
Justice Strathy stated: While it has been necessary for me to. While on a certification motion the plaintiff is only required.
As such bringing a summary judgment motion at the same. It permits defendants to gauge the likelihood of how things might.
Footnotes. 1. The minimum donation was $1. Over 1. 70. 0 donors donated between. The charity was entitled to keep 1% of each donation. TTL in order to participate in the.
Gift Program. This was part of the back- end of the program. The. funds paid by the charity to TTL were to be invested by TTL on. Justice Strathy. described the process: "TTL established a leveraged cash and. The charity was to receive a. TLL was to receive 2. The charity was never to receive a return on.
Park. Lane, TTL, and Trafalgar Associates Limited (TAL). Ontario Corporation which was also incorporated by Mr.
Furtak. and which worked in conjunction with Park. Lane to create, promote. Gift Program). 4. A registered charity created in 2. FFC Foundation's.
C. R. A. 5. Mr. Gleeson was the founding director of FFC. Foundation and the original trustee of the Donations Canada Trust. Ms. Gleeson was and continues to be the Executive Director of FFC. Foundation. 6. Appleby is an independent corporate trustee, based in. Bermuda. 7. Concerning the cause of action requirement in s. Class Proceedings Act, 1.
Justice. Strathy held that the plaintiff had pleaded the following causes of. Park. Lane. Defendants, Appleby, FFC Foundation, the Gleesons, and the. Lawyers); negligent misrepresentation (Park. Lane Defendants, the. Gleesons, and the Lawyers); fraud and fraudulent misrepresentation. Park. Lane Defendants, Appleby, and the Gleesons); Conspiracy.
Park. Lane Defendants, Appleby and the Gleesons); breach of the. Consumer Protection Act, 2.
Park. Lane Defendants, FFC. Foundation, and the Gleesons); breach of contract (Park. Lane); and. unjust enrichment and constructive trust (Park. Lane Defendants, FFC. Foundation, the Gleesons, and Appleby). Deep v. M. D. Management; Singer v. Schering- Plough Canada.
Inc.; Silver v. Imax. Corp. 9. Dobbie v.
Arctic Glacier Income. Fund; Lipson v. Cassels Brock & Blackwell. LLP1. 0 On the issue of waiver of tort, even though the. Justice Strathy stated. And, that "the. availability of waiver of tort, and its scope, is an open question.
For a summary of the defendants against which each. For. reasons see paragraphs 2. The issue of whether the Class.
Members were entitled to damages and prejudgment interest including. C. R. A. in respect of their tax assessments and their out of pocket. C. R. A. tax reassessments was. The content of this article is intended to provide a general. Specialist advice should be sought.
Nova Scotians settle class action. BRUCE ERSKINE BUSINESS REPORTERPublished December 2, 2.
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