Two appeals will be heard tomorrow morning by the Supreme Court of Canada in rectification decisions from the Quebec courts. The first appeal is Agence du Revenu du Québec (formerly the Deputy Minister of Revenue of Quebec) v. Services Environnementaux AES Inc., et al. while the second appeal is Agence du Revenu du Québec v. Jean Riopel, et al. In each case, the Quebec Court of Appeal agreed with the taxpayers that rectification was in order.
The Supreme Court's summary of the first appeal may be found here. Each factum in the first appeal may be read here.
The Supreme Court's summary of the second appeal may be found here. Each factum in the second appeal may be read here.
The decision of the Quebec Court of Appeal in the first appeal is here. The decision of the Quebec Court of Appeal in the second appeal is here.
At 9:30 a.m. tomorrow, the live webcast of the hearings may be viewed here or here. The archived webcast will be available for viewing a day or two later.
The newest member of the Supreme Court of Canada, Justice Richard Wagner, was a member of the panel of the Quebec Court of Appeal that decided the second appeal. He will, therefore, not hear tomorrow's appeals. Accordingly, a maximum of seven judges will be on the panel tomorrow morning.
We will publish a blog post by the end of the day tomorrow reporting on the arguments in the Supreme Court of Canada.
For more information, visit our Canadian Tax Litigation blog at www.canadiantaxlitigation.com
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