With the passing of this new section, the Minister is now allowed to collect 50% of the amount assessed in respect of a tax shelter even if the related assessment is in dispute. Meaning even if you object, or appeal to Tax Court, the Minister can still come after you for half the amount owing. This is in stark contrast to how the law used to be.
This is just one of the many provisions that the Government of Canada has enacted in an attempt to stop abusive tax shelters. If your charitable tax receipt reads more than the actual cash you have contributed, it is likely that the Canada Revenue Agency will want to speak with you.