Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper

Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 303

AG as respondent (p. 42:4)

The proper name of the respondent on an application for judicial review of a taxpayer relief decision under subsection...

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Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 317

Request for certified tribunal record (p.42:4)

At the time of filing the notice of application or at a later time, an applicant may make a request...

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Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 71

Electronic filing (p.42:5)

Recent amendments to the rules have made the judicial review process less paper-intensive. For example, the Federal...

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Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 306

Filing with application records (p. 42:5)

Another example of a paper-saving measure is found in rules 306 and 307, recently amended so that the...

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Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 65

Double-sided documents (other than authorities) rejected (p. 42:5)

...A double-sided document may not be accepted for filing in the registry,...

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Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 114

Group or representative proceedings (pp. 42:9-10)

...In situations where the minister issues a decision or decisions that apply to all members of...

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Summary Under
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1)

General reasonableness standard (p. 42:6-7)

In general, the standard of review that the reviewing court will apply to the minister's decision on...

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