Orders For Consolidation And Common Hearings Under Tax Court Rule 26

Overview of Rule 26

Section 26 of the Tax Court of Canada Rules (General Procedure)¹ (the "Tax Court Rules"), referred to as "Rule 26", can be useful where multiple taxpayers are involved in related matters and are simultaneously appealing their respective assessments before the Tax Court, or where a single taxpayer has separately appealed different reassessments. Rule 26 provides litigants before the Tax Court with the ability to consolidate two or more proceedings, have the proceedings heard at the same time or sequentially, or to stay a proceeding until the determination of another. The rule provides: