Words and Phrases - "decision"

a
93
b
44
c
87
d
58
e
43
f
32
g
20
h
15
i
77
j
2
k
3
l
32
m
63
n
29
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42
p
83
q
3
r
80
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96
t
48
u
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v
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w
25
y
2

Hillcore Financial Corporation v. Canada (Attorney General), 2025 FC 2009

Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 18.1 - Subsection 18.1(2)
CRA’s verbal “courtesy response,” rejecting refunding of a GST credit which it had already set-off, years before, against an ITA debt, instead was a reviewable decision

approximately $0.9 million (the “seized funds”) on account of the total GST debt of $1.7 million . However, in July 2020, CRA vacated the...

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Words and Phrases
decision
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 296 - Subsection 296(6) strong argument that CRA had an obligation to return garnished funds following vacating of GST reassessments, notwithstanding outstanding ITA balance 348
Tax Topics - Income Tax Act - Section 224.1 strong argument that GST credit balance representing obligation to return garnished funds could not be set off against ITA balance 171

Prince v. Canada (National Revenue), 2019 FC 348, aff'd 2020 FCA 32

Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 18.1 - Subsection 18.1(3)
30-day letter was not a judicially-reviewable “decision”

The taxpayer’s counsel filed a no-name application under the CRA’s voluntary disclosure program (VDP), which CRA subsequently rejected on the...

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Words and Phrases
decision
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) no prejudice in issuance of reassessment before completion of VDP process 227