Over the past several years, the Canada Revenue Agency (the
"CRA") has been in the midst of a digital service
transformation. Like the CBSA's "CARM" project, which
we previously discussed
here, this initiative appears to be a response to the Canadian
government's "
digital first" policy, which aims to build digital
delivery into government operations and services.
While the CRA now provides Notices of Assessment electronically
through online portals including "My Account" and
"My Business Account", access to such documents remains
difficult for many, especially non-Canadian residents who may be
unfamiliar with the Canadian tax system.
Case Study: McIntyre v. The King
A prime example of such challenges was highlighted in the 2023
Tax Court of Canada ("TCC") case of
McIntyre v. The King (2023, TCC 118). In this case, a
taxpayer who was assessed by the CRA to owe more than $17,000 had
not received and could not obtain copies of the assessments giving
rise to
