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Canada Case Law

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Income tax act 2026 TCC 31

Opheim v. The King

Motion to designate David Hawreluk as a sole lead case was dismissed. The Court held Rule 146.1 requires consent of each party and that the requested direction was not in the interests of justice.

  • Lead case designation
  • Rule 146.1
  • General anti-avoidance rule (gaar)
  • Case management
  • Costs
  • Lead-case-designation
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Tax law 2026 TCC 21

Opheim v. The King

The Tax Court denied party status to the Hawreluk respondent in a lead-case motion, but allowed use of Hawreluk discovery for the motion under the implied undertaking rule.

  • Lead case designation
  • Intervention / leave to intervene
  • Implied undertaking rule
  • Case management (rule 146.1)
  • Lead-case-designation
  • Intervention
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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.