Author: Florence Sauve

Taxpayers regularly argue that an administrative policy adopted by the Canada Revenue Agency (the “CRA”) constitutes an incorrect interpretation of the law that courts should reject.  Courts sometimes side with these taxpayers, and choose not to follow the CRA’s administrative…

Traditionally, the Tax Court only awarded costs that deviated from the Tariff annexed to the Tax Court of Canada Rules (General Procedure) (the “Rules”) in the presence of reprehensible, scandalous or outrageous conduct on the part of one of the…