Wilson: SCC Overhauls Standard of Review?
Tax professionals who advise clients on judicial review of the CRA’s discretionary decisions should monitor developments in the standard of review in […]
Judicial Review
Gordon: CRA May Not Fetter Discretion on Interest Relief Application
FC Dismisses JR Application for Delay
McNally: CRA Does Not Have Unfettered Discretion to Delay Assessment
ConocoPhillips: FCA Confirms Tax Court’s Jurisdiction to Determine Questions of Timing and the Validity of a Notice of Objection
In ConocoPhillips Canada Resources Corp. v. The Queen (2014 FCA 297), the Federal Court of Appeal overturned a Federal Court decision (2013 […]
Foreign-based Requirement Under Section 231.6 of the Income Tax Act Upheld by the Federal Court
The Canada Revenue Agency had an important win this week in its efforts to access information outside of Canada. On […]
Federal Court of Appeal deals a blow to the Canada Revenue Agency: Full disclosure must be made on ex parte applications
On February 21, 2013, the Federal Court of Appeal released two decisions related to the obligations of the Minister of National Revenue […]
Federal Court Cancels its Earlier Orders Authorizing Issuance of “Unnamed Persons” Requirements as Canada Revenue Agency Failed to Disclose all Relevant Facts
The decision of the Federal Court in Minister of National Revenue v. RBC Life Insurance Company et al., 2011 FC […]
Federal Court Calls CRA’s Reasons “Inadequate” on Denial of Fairness Request
On October 21, 2011, the Federal Court (Justice Sandra Simpson) released her decision on an application for judicial review in […]