The Supreme Court of Canada dismissed the appeal of the taxpayer in Guindon v The Queen, 2015 SCC 41. The majority of the Court exercised its discretion to address the merits of the taxpayer’s constitutional arguments despite the taxpayer’s failure to give the required notice of constitutional questions in the lower courts and held that the third-party penalty proceedings under s.163.2 of the Income Tax Act (Canada) are administrative in nature and therefore not subject to the protections under s.11 of the Canadian Charter of Rights and Freedoms.