A discretionary remedy for exceptional cases where the strict application of Canadian tax law leads to an unjust or inequitable outcome.
Cases involving severe financial hardship or personal misfortune.
Where enforcement is unreasonable or inconsistent with legislative intent.
Undue tax consequences resulting from a CRA error or significant delay.
Situations that are clearly beyond the taxpayer’s control.
Only available when no other legislative remedy or appeal exists.
Compelling humanitarian or public policy considerations are present.
Remission requests are an extraordinary remedy and are granted infrequently.
The application must clearly show that the outcome is fundamentally inequitable.
The case must argue that collecting the tax would be contrary to principles of good governance.
It must be shown that enforcement would harm public confidence in the tax system's fairness.
Evaluating the legal basis and exploring all alternative remedies first.
Preparing submissions aligned with the CRA’s Remission Guide.
Compiling and presenting all supporting evidence (medical, financial, procedural).
Liaising with the CRA Legislative Policy and Regulatory Affairs Branch.
Advancing arguments that meet the high threshold required under the FAA.
Advising on options after a decision, including potential judicial review.
Evaluate legal basis for remission and compile all supporting evidence.
Prepare a comprehensive submission for the CRA and Department of Finance.
Liaise with the CRA during their review and policy analysis.
Receive final decision and advise on post-decision options.
In-depth understanding of the high threshold required for this unique remedy.
Experience preparing submissions aligned with CRA and Dept. of Finance policy.
Skilled at liaising with the Legislative Policy and Regulatory Affairs Branch.
Guidance from initial assessment to post-decision options like judicial review.