Federal Court of Appeals to CRA: You MUST explain your decisions (much scathing commentary involved)

2025 FCA 225

This has to be one of the funnier (and short!) tax cases to be decided at the FCA…which, after all, is the second-highest Court in Canada. Stratas J.A. includes such comments as:

“[7] The grounds for distinguishing Bonnybrook? It’s pretty much a mystery. The analysis and reasoning in support of whatever grounds the Agency was invoking? Nothing.”

“[8] The grounds for saying that the reasoning in Bonnybrook does not apply to subsection 164(1) of the Act, the relevant section here, a different section from that considered in Bonnybrook? Again nothing.”

“[9] The Canada Revenue Agency did say this to the appellant: “subsection 220(3) may not be relied on by the Minister to exercise discretion to extend the deadline in subsection 164(1) of the Act”. Why? That’s pretty much a mystery too.”

It’s a fun read…not technical, and rather amusing except for the likely fact that it probably cost the taxpayer involved a considerable sum to bring the case … just to get a Judicial Review because CRA refused to provide ANY commentary on their decision to refuse the t/p’s request.

For your reading amusement:

https://www.canlii.org/en/ca/fca/doc/2025/2025fca225/2025fca225.html?resultId=ac4000b51f0e4ce9a456c31fa10bc06c&searchId=2025-12-16T15:19:21:736/8019a814dc354327a8eb1eb632f6143d

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