VANCOUVER — A British Columbia couple who ran educational seminars promoting the bogus notion that people don’t have to pay taxes have lost their appeal against tax bills on $1.4 million in revenue from the scheme.
The Federal Court of Appeal in Vancouver ruled this week that Russell Porisky and Elaine Gould’s appeal of the tax assessments on revenue generated between 2004 and 2008 had “no merit,” after the Tax Court of Canada rejected their arguments last year.
Porisky and Gould were convicted of tax evasion in 2016, years after they ran educational seminars under the banner of Paradigm Education Group, which promoted ways to avoid taxation that they believed was a form of slavery.
The Tax Court of Canada ruled last year that Gould and Porisky did derive taxable income from Paradigms activities, finding they offered “a convoluted and head-spinning interpretation of the tax legislation that relies on semantics to say that the Income Tax Act and Excise Tax Act do not apply to their situation.”
“The Paradigm system was based on the view that the tax legislation can be interpreted in such a way as to allow one to opt out of paying income tax or collecting GST,” the Tax Court ruling says.
Both Porisky and Gould were assessed for failing to report more than $569,000 in income earned between 2004 and 2008, and were also given penalties for “gross negligence.”
Porisky told the court that he came to believe that there was a “duality” between taxpayers, a distinction between so-called “natural versus artificial” persons which could be used to opt out of paying taxes.
“He explained that in his view, income tax was actually a labour tax resulting in a form of slavery, which in turn was a crime against humanity,” Judge Susan Wong wrote.
Wong’s ruling says Porisky was sentenced to five and a half years in prison for tax evasion and counselling to commit fraud, and fined more than $239,000.
Gould, the ruling says, was sentenced to six months in prison and fined more than $38,000 for income tax evasion. She was held liable for 20 per cent of the tax evasion scheme and Porisky the other 80 per cent.
The Appeal Court ruling says Porisky and Gould held seminars, sold tickets, wrote books and training materials under the Paradigm name, generating $1.4 million over five years while reporting no income and paying no tax.
The ruling says their appeal hinged on Porisky’s interpretation of a Supreme Court of Canada ruling, believing that “because they claim they had no subjective intention to earn a profit, the appellants’ activities were not a source of income, but a personal endeavour.”
The three-judge panel found those views have been “consistently” rejected by the court, and that the appeal had no merit, dismissing the case years after the couple were convicted of tax evasion and sent to prison.
Porisky and Gould did not have a lawyer arguing their case and neither could not be reached for comment on the latest ruling.
Several followers and “educators” who were involved with Paradigm have also been charged, convicted and fined.
The Canada Revenue Agency announced in December 2022 that Eric Ho of Richmond, B.C., had been sentenced to 30 months in jail and fined more than $122,000 for tax evasion and counselling to commit fraud after a decade “on the run” from the charges.
The agency said Ho was a Paradigm “educator” who failed to report more than $582,000 in income between 2004 and 2008.
West Vancouver dentist Dr. Peter Balough was given an 18-month conditional sentence and fined more than $578,000 for tax evasion in B.C. Provincial Court.
The agency began investigating Balough after he began invoicing his own dental practice as a contractor in 2005, finding he “was an adherent of the Paradigm Education Group which promoted the pseudo‑legal notion that a person can self‑classify as a ‘natural person’, and thereby be exempt from the payment of income tax.”
The Canada Revenue Agency characterizes such people as “tax protesters (who) support the false notion that they do not have to pay tax on income they earn.”
This report by The Canadian Press was first published Nov. 6, 2025.
Darryl Greer, The Canadian Press
