In Barrs v The Queen et al, the taxpayer, Mr. Randall Barrs, appealed to the Federal Court of Appeal after the Federal Court dismissed his application for judicial review of the Canada Revenue Agency’s (CRA) decision to deny him additional relief from accrued interest. In 1984, Mr. Barrs and...
Introduction: Settling Tax Litigation in Canada Tax settlements play a vital role in tax administration and enforcement. It would be burdensome and impractical to litigate every tax dispute in Tax Court. When entering settlement discussions with the Canadian tax-litigation lawyer for the Canada Revenue Agency, taxpayers must carefully assess...
Introduction: Rectification & Its Tax Consequences Rectification is an equitable remedy. It allows parties to correct drafting errors that would otherwise render a legal instrument incompatible with the agreement that the instrument was meant to document. In these cases, the contracting parties may ask a court to rectify the...