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Canada Case Law

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Tax

Russell v. The King

The Tax Court struck specified paragraphs of the Amended Notice of Appeal, holding they alleged CRA misconduct, Charter breaches, and relief outside its jurisdiction.

  • Motion to strike
  • Jurisdiction of the tax court of canada
  • Reasonable grounds for appeal
  • Procedural fairness
  • Abuse of process
  • Section 7 charter
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Employment insurance

Lees v. M.N.R.

The Tax Court held that Chelsea Lees was an employee, not an independent contractor, of SXNM Successionmatching Ltd. for EI and CPP purposes.

  • Employee versus independent contractor
  • Insurable employment
  • Pensionable employment
  • Canada pension plan
  • Employment insurance act
  • Employee-versus-independent-contractor
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Tax

2520356 Ontario Corp. v. The King

Appeal partly allowed on HST reassessment. The Court held the property sale was exempt because the renovation was abandoned after demolition and before substantial reconstruction.

  • Residential complex
  • Substantial renovation
  • Builder status
  • Input tax credits
  • Exempt supply
  • Assessment and reassessment
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Tax

Harris v. The King

The Tax Court dismissed a motion to stop CRA collection and return garnished funds, holding it lacked jurisdiction for that relief; the records request was premature.

  • Gst/hst reassessment appeal
  • Collection and garnishment
  • Injunction / stay of collection
  • Court jurisdiction
  • Timetable order / discovery
  • Gst-hst
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Tax 2026 FC 547

Toor v. Canada (Attorney General)

The Federal Court dismissed two judicial review applications challenging the Minister’s partial denial of taxpayer relief for interest and penalties under s. 281.1 of the Excise Tax Act.

  • Taxpayer relief
  • Interest and penalties
  • Excise tax act s.281.1
  • Procedural fairness
  • Financial hardship
  • Covid-19 delays
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Tax 2026 TCC 62

Brass Collar Capital Corp. v. The King

The Tax Court struck moot portions of Brass Collar’s appeal and parts of an affidavit, holding there was no live tax controversy and no basis to continue.

  • Income tax act
  • Income tax regulations s.306
  • Tax court jurisdiction
  • Mootness doctrine
  • Motion to strike pleadings
  • Affidavit admissibility
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Tax 2026 TCC 61

2251102 Ontario Inc. v. The King

Appeals dismissed in a Tax Court net worth reassessment case involving unreported corporate income, COGS adjustments, and shareholder benefits.

  • Net worth assessment
  • Shareholder benefits (s.15(1))
  • Books and records (s.230(1))
  • Assessment technique (s.152(7),(8))
  • Cost of goods sold disallowance
  • Net-worth-assessment
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Tax 2026 TCC 38

Twisted Leaves Ltd. v. The King

The Tax Court of Canada allowed an application, finding credible evidence that a GST Notice of Objection was effectively transmitted on August 20, 2024.

  • Extension of time
  • Filing date deeming
  • Notice of objection
  • Rule 4.2
  • Rule 19(3) interests of justice
  • Evidence credibility
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Tax 2026 FC 208

Rawlings v. Canada (Attorney General)

The Federal Court found the CRA’s decision unreasonable for failing to address Rawlings’ actual request to amend his 2004 tax return and ordered expedited redetermination.

  • Taxpayer relief
  • Amendment of tax return
  • Reasonableness review
  • Procedural fairness
  • Taxpayer-relief
  • Amendment-of-tax-return
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Tax 2026 TCC 27

Caddell v. The King

Two GST/HST appeals were denied. The Tax Court found the appellants were builders, made a self-supply of their home, could not use the personal-use exception, and owed tax based on a $915,000 value.

  • Self-supply
  • Builder
  • Subsection 191(5) exception
  • Fair market value
  • Gst-hst
  • Fair-market-value
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About this LexChat collection

Canada decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.