When the CRA makes a decision that is unreasonable, procedurally unfair, or outside its legal authority, judicial review is the appropriate legal remedy. It is a challenge to the legality, fairness, or reasonableness of how that decision was made.
The CRA did not follow fair and proper procedures in its decision-making.
The decision lacks a rational basis or is not supported by the evidence.
The CRA exceeded its legal authority or acted outside its jurisdiction.
The decision was based on an incorrect interpretation of the law.
Challenging decisions to deny relief from penalties and interest.
Reviewing the refusal of a taxpayer's application under the Voluntary Disclosures Program.
Contesting the CRA's refusal to grant an extension to file a Notice of Objection.
Reviewing unfair or improper conduct during audits or collections.
Assessing whether judicial review is appropriate and advisable for your case.
Preparing and filing the application with all supporting legal materials.
Representing clients in hearings and arguing the merits of the case.
Advising on settlement options and any available post-decision remedies.
Strict deadlines apply—most judicial reviews must be filed within 30 days of the CRA’s decision. Delay can eliminate your right to challenge the decision entirely.
We understand both technical tax issues and administrative law principles.
We build compelling arguments that protect your rights and hold the CRA accountable.
Thorough evaluation of whether judicial review is the right path forward.
Full support through every stage of the Federal Court judicial review process.