It’s not every lawyer who can plausibly quote Henry IV, Part 1, in an article on tax matters, but Neal Armstrong pulls it off in a recent post about MNR v Sifto Canada Corp, 2014 FCA 140. In Sifto, Sharlow JA wrote that the Federal Court could issue “a declaration that the penalties should not have been assessed in the face of the valid voluntary disclosure”, to which Mr Armstrong responded:
It is not clear whether she is referring to a Henry IV, Pt. 1-style declaration: GLENDOWER-I can call spirits from the vasty deep. HOTSPUR-Why, so can I, or so can any man, but will they come when you do call for them?
