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Published: January 25, 2022

Last Updated: October 21, 2022

Case Issue

The client came to us to represent his corporation, locked out of its premises, pending a Goods and Services Tax/Harmonized Sales Tax (GST/HST) appeal in Tax Court. The books and records of the corporation had been seized, so the Canada Revenue Agency (CRA) assessed an arbitrary amount of $79,852.83 for the corporation’s GST/HST liability for the relevant period. 


After going through the records, we discovered the client had been assessed personally as director of the corporation. We filed a notice of objection with the CRA on the basis that the director had been duly diligent in fulfilling the corporation’s tax obligations. The Crown agreed to put the Tax Court appeal of the corporation on hold until the CRA decides on the objection.


The CRA allowed the objection and vacated the liability assessment of $79,852.83 for GST/HST without the need to proceed to expensive litigation.


"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

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