Published: October 8, 2024
This article discusses 2024 case law in relation to the Federal Court’s jurisdiction to quash abusive CRA decisions, including Milgram Foundation and Dow Chemical. After the Supreme Court of Canada clarified the boundaries between jurisdictions of the Tax Court of Canada and the Federal Court in Dow Chemical, Milgram Foundation, is now considered a remarkable victory for taxpayers in Canada, which narrowed the definition of a “collateral attack” on tax assessments and granted taxpayers opportunities to challenge abusive CRA decisions to assess at the Federal Court.
Disclaimer:
"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."
