Ontario Superior Court rules CRA not entitled to notice of rectification

In the recent decision in Canada v. Brogan Family Trust (2014 ONSC 6354), the Ontario Superior Court of Justice dismissed a motion by the Attorney General of Canada to set aside a rectification order. The court held that the Canada Revenue Agency is not necessarily entitled to be given notice of proposed rectification proceedings. A copy of the court’s decision is available here.

Prepared by: E. Rebecca Potter

Becky Potter is a seasoned tax litigator and a partner based out of the firm’s Toronto office. Becky brings a strategic and practical approach to tax disputes, and is known for her ability to distill complex technical tax matters down… more »

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