The Supreme Court has upheld the so-called "preparer penalties under subsection 163.2 of the Income Tax Act as proper administrative penalties. In this matter, a lawyer who had been paid $1,000 for her legal opinion was fined $547,000 by the CRA for her role in issuing charitable donation receipts in a tax scheme organized by others. Refer to Guindon v. Canada, 2015 SCC 41 (CanLII)