Archibald – Federal Court of Appeal confirms that taxpayers cannot rely on favourable CRA treatment of similarly-situated taxpayers

In the course of dismissing the taxpayer’s appeal of an assessment made on the basis that tuition fees paid to the University of Liverpool for an on-line MBA program did not qualify for the tuition tax credit, Woods J.A. stated that it is “well settled that a taxpayer does not become entitled to relief simply because another taxpayer similarly situated was assessed differently.”

Neal Armstrong. Summaries of Archibald v. Canada, 2018 FCA 2 under s. 118.5(1)(b) and s. 152(1).