Judicial Review
If you are of the view that the CRA did not exercise its discretion in a proper manner when considering and rendering a decision that impacts you or your company, you may be able to apply to the Federal Court of Canada for a judicial review. However, strict time limits apply and you must generally apply within thirty (30) days from the date of the decision.
The purpose of a judicial review is not to change the CRA decision, but to establish that the CRA did not exercise its discretion properly and it should be asked to consider the matter again. Consequently, if the Federal Court determines in your favour, the court will send the matter back to the CRA for another review and for further consideration.
Applying for a judicial review is not an easy task. It involves a number of formalities in addition to a relatively short deadline. Proper and skilled professional support is strongly recommended.
Contact us in confidence and with the protection of solicitor client privilege to discuss your or your client's personal situation and let us start to help you.