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The recent Quebec case of Groupe Enico & Archambault v. Revenu Québec, 2013 QCCS 5189 is another case in which a developing duty of care by the CRA to taxpayers is being recognized by the courts in different provinces. The taxpayers were awarded $4 million, including $2 million in punitive damages, for an abusive GST/QST assessment and collection action. While it is becoming accepted law that the CRA has liability to taxpayers for improper actions the case is currently under appeal to the Quebec Court of Appeal.

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