Two appeals will be heard tomorrow morning by the Supreme Court of Canada in rectification decisions from the Quebec courts. The first appeal is Agence du Revenu du Québec (formerly the Deputy Minister of Revenue of Quebec) v. Services Environnementaux AES Inc., et al. while the second appeal is Agence du Revenu du Québec v. Jean Riopel, et al. In each case, the Quebec Court of Appeal agreed with the taxpayers that rectification was in order.
The newest member of the Supreme Court of Canada, Justice Richard Wagner, was a member of the panel of the Quebec Court of Appeal that decided the second appeal. He will, therefore, not hear tomorrow’s appeals. Accordingly, a maximum of seven judges will be on the panel tomorrow morning.
Postscript: At the conclusion of the hearing, the panel reserved judgment. During the course of the hearing, highlights of argument were tweeted live @CanTaxLit