Taxpayer Relief update

Taxpayer Relief update

In Bozzer v. Her Majesty the Queen (“Bozzer”), Federal Court of Appeal held that the taxpayer relief provisions contained in the Income Tax Act allow the Minister of National Revenue (“Minister”) and Canada Revenue Agency (“CRA”) to cancel interest accrued in any taxation year ending within ten years before the taxpayer’s application for relief, regardless of when the underlying tax debt arose.

The Minister and the CRA have, in some circumstances, attempted to disregard the common law. We have been waiting for the CRA to announce its response to the Bozzer decision.

Today, the CRA distributed a news release entitled Taxpayer relief deadline is December 31, 2011. This news release confirms that the CRA will follow the Federal Court of Appeal’s decision in Bozzer. In addition, the CRA announced that it will adopt this change for requests for taxpayer relief made under the Air Travellers Security Charge Act, Softwood Lumber Products Export Charge Act and the Excise Act.


Susan Farina wearing a dark blue top and dark rimmed circular glasses brightly smiling while sitting at a desk with a pen and paperwork in front of her

What Accountants Say

Peter Aprile is a very hands on and practical tax lawyer who is very focused and diligent. He is a pleasure to work with.

- Susan Farina, Tax Partner, Price Waterhouse Coopers

David Cuddy in a blue button up shirt standing in a park

What Clients Say

I’m a Senior VP with an accounting and finance background. I’ve worked with lawyers and large law firms. I was referred to Counter to fix a tax dispute. It is very rare to encounter lawyers that combine expertise, dedication, and a businesslike approach to litigation. I have no hesitation in recommending Counter.

- David Cuddy, Senior Vice-President, Finance & Business Operations, CFL

Laura Couvrette smiling in a plaid top standing with arms folded

What Accountants Say

Counter Tax Litigators has worked with Fuller Landau to resolve several of our clients’ tax disputes. Counter delivers superior communication.

- Laura Couvrette, CPA, CA, Fuller Landau LLP

Mark Ram standing in a office hallway wearing a white button up with dark blue jacket and dark rimmed glasses

What Clients Say

I spent a good part of my career dealing with attorneys on innumerable matters, and found Peter to be extremely competent, open-minded and exceptionally honest. I would not hesitate to use Peter again, and highly recommend the team at Counter Tax Litigators.

- Mark Ram, Retired CEO

Klaus W. Reif sitting at a desk, dressed in a blue jacket with a silver wrist watch

What Clients Say

Counter’s representation on our behalf was well informed, professional and efficient, which ultimately resulted in a highly satisfactory decision in all aspects.

- Klaus W. Reif, President, Reif Estate Winery

Brian Grott wearing a white button up with a red tie with white dots, softly smiling and leaning against a desk

What Clients Say

I was amazed with the results. They went above and beyond, and I would recommend Counter to any person or business with a significant tax dispute.

- Brian Grott, Northland Screen Corp

How can we help you?


Our law firm and tax lawyers regularly receive
recognition as leaders in tax controversy and litigation.