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Canada Case Law

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Tax law 2022 FC 1488

Bélanger v. Canada (National Revenue)

The Federal Court dismissed Lyse Bélanger’s judicial review of the refusal to recommend tax remission, holding the decision was reasonable and supported by the record.

  • Remission of taxes
  • Financial administration act s.23(2)
  • Income tax act s.220(3.1)
  • Tax remission criteria
  • Interest relief
  • Judicial-review
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Tax law 2021 FC 788

Anderton v. Canada (Attorney General)

The Federal Court dismissed two judicial review applications challenging CRA remission refusals for tax, interest, and penalties, finding the decisions reasonable.

  • Remission of taxes
  • Financial administration act s.23(2)
  • Reasonableness standard of review
  • Extreme hardship
  • Public interest
  • Judicial-review
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Administrative law 2020 FC 1027

Mokrycke v. Canada (Attorney General)

The Federal Court allowed judicial review of a refusal to recommend tax remission, finding the decision unreasonable because it failed to address the applicant’s central arguments.

  • Remission of taxes
  • Financial administration act s.23
  • Procedural fairness
  • Reasonableness review
  • Remission guidelines
  • Tax reassessment
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Tax law 2019 FC 574

Internorth Ltd. v. Canada (National Revenue)

La Cour fédérale a conclu que le refus de remise était raisonnable et a rejeté la demande de contrôle judiciaire, avec dépens contre la demanderesse.

  • Remission of taxes
  • Director's liability for source deductions
  • Statute of limitations on appeals
  • Reasonableness review
  • Use of remission to bypass appeals
  • Remission-of-taxes
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Administrative law 2019 FC 210

Boivin v. Canada (Attorney General)

Judicial review of a refusal to recommend tax remission was dismissed. The Court held the Assistant Commissioner’s decision was reasonable and supported by CRA records.

  • Remission of taxes
  • Reasonableness standard
  • Financial administration act s.23(2)
  • Cra remission guidelines
  • Notices of assessment
  • Judicial-review
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Taxation 2018 FC 494

Pay Audio Services Limited Partnership v. Canada (National Revenue)

The Federal Court upheld a refusal to recommend remission of HST, interest, and penalties, finding the Minister’s delegate reasonably considered the facts and did not fetter discretion.

  • Remission of taxes
  • Harmonized sales tax (hst)
  • Financial administration act s.23
  • Fettering of discretion
  • Reasonableness standard of review
  • Excise tax act provisions
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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.