We have previously written about jurisdictional issues between the Tax Court of Canada (“TCC”) and Provincial Superior Courts here. A recent decision of the TCC – Desjardins v. the King, 2026 CCI 109 [Desjardins] – further illustrates the tricky nature of jurisdiction in tax disputes and that getting the forum correct is not a simple task.
In this update to our Tax Appeal Series on jurisdiction in tax disputes, we review the Desjardins decision with a view to highlighting the complicated task of statutory interpretation and its intersection with jurisdiction in tax disputes.
In the recent Tax Court of Canada (“TCC”) decision Harris v. The King, 2026 TCC 89 (“Harris”), a taxpayer assessed for unremitted GST/HST learned the hard way about the Canada Revenue Agency’s (“CRA”) extremely broad Collection Rights.
In this Tax Audits Series we review the Harris decision and the key differences it highlights between the CRA’s ability to collect GST/HST debts and Income Tax debts – and why it demonstrates that retaining Experienced Tax Counsel at the front-end of the audit process can help avoid harsh collections action later on.
The recent decision of the Tax Court of Canada (“TCC”) in Refind Environment Inc. v. The King (2024 TCC 2) is a poignant reminder of the importance of filing deadlines.
In Refind, the TCC dismissed an application for an extension of time to file a Notice of Objection against assessments under the Excise Tax Act (“ETA”) because the Registrant was one (1) day latein filing their application for an extension of time to the Minister of National Revenue (the “Minister”)!
