Informal Procedure Tax Court of Canada Chief Justice Eugene Rossiter, Tax Court of Canada Justice Wyman W. Webb, Federal Court of Appeal

Aim of the Informal Procedure Differences between the Informal Procedure and the General Procedure Differences between the Tax Court and the Federal Court of Appeal

Tax Court statistics

Considerations for an agent before deciding to represent a taxpayer on an appeal to the Tax Court Before Federal Court of Appeal – the individual taxpayer can act in person or be represented by a solicitor (Rule 119) Rule 121 provides for a possible exception, in special circumstances and with Court approval, if the individual taxpayer is under a legal disability

Feeling of a taxpayer that the auditor’s treatment was unfair – can the Tax Court consider this?

Importance of pleadings What information does the Tax Court have before the appeal is heard? What information does the Federal Court of Appeal have before the appeal is heard?

How important is preparation?

Scheduling of cases Adjournments

Most common mistakes made by self-represented taxpayers

Rules of evidence Witnesses Documents

Should the taxpayer attend the hearing?

Pre-hearing discussions with witnesses

Settlements – When? Where? How? Why?