In Grenon v. Canada (Fed CA, 2025) the Federal Court of Appeal notes the duties of the Minister of National Revenue:
[305] The Minister has a statutory duty to assess the tax payable in accordance with the facts and the law: Canada (Attorney General) v. Collins Family Trust, 2022 SCC 26, [2022] 1 S.C.R. 747 at para. 26, citing CIBC World Markets Inc. v. Canada, 2012 FCA 3, 426 N.R. 182 at paras. 16, 20-21; Galway v. Minister of National Revenue, 1974 CanLII 2465 (FCA), [1974] 1 F.C. 600, 2 N.R. 324 (F.C.A.) at 602; Canada v. 984274 Alberta Inc., 2020 FCA 125, [2020] 4 F.C.R. 384 at para. 52, leave to appeal to SCC refused, 39355 (29 April 2021). Here, the Minister concluded, and the Tax Court agreed, that Grenon RRSP acquired NQI.
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