ARTICLE · 08 APRIL 2019

Action In Damages Against Revenu Québec: Recent Developments

Spiegel Sohmer

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The recent judgment Naples Pizza (1981) inc. c. Agence du revenu du Québec, 2019 QCCS 710 delivers some developments of interest, particularly with respect to prescription and the extra-contractual

CanadaTax

Jonathan Éthier

The recent judgment Naples Pizza (1981) inc. c. Agence du revenu du Québec, 2019 QCCS 710 delivers some developments of interest, particularly with respect to prescription and the extra-contractual liability of Revenu Québec.

In this case, the Superior Court ruled on actions for damages instituted by a corporation operating a pizzeria and by one of its shareholders who was also a director. Revenu Québec was reproached for using an alternative audit method and for having cancelled tax assessments the day before a hearing. Ultimately, the Court declared the shareholder's action inadmissible and rejected the corporation's action, which sought compensation for its professional fees incurred.

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