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ARTICLE · 25 JUNE 2026

TCC Powerless Over Cra Collections

Millar Kreklewetz
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The Canada Revenue Agency possesses extraordinarily broad collection powers when it comes to unremitted GST/HST, even while taxpayer appeals remain pending before the Tax Court of Canada. A recent TCC decision reveals the stark limitations on judicial intervention in CRA collection activities and highlights critical differences between GST/HST and income tax collection mechanisms. Understanding these distinctions proves essential for taxpayers facing GST/HST assessments, as the window for effective legal in

CanadaTax
Robert Kreklewetz
Robert Kreklewetz
Isaac Thompson
Isaac Thompson

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In the recent Tax Court of Canada (“TCC”) decision Harris v. The King, 2026 TCC 89 (“Harris”), a taxpayer assessed for unremitted GST/HST learned the hard way about the Canada Revenue Agency’s (“CRA”) extremely broad Collection Rights.

In this Tax Audits Series we review the Harris decision and the key differences it highlights between the CRA’s ability to collect GST/HST debts and Income Tax debts – and why it demonstrates that retaining Experienced Tax Counsel at the front-end of the audit process can help avoid harsh collections action later on.

Background to the Harris Decision

In Harris, the TCC dismissed the taxpayer’s motion to (1) block the CRA from garnishing his funds in order to recover unpaid GST/HST; and (2) return the funds already garnished.

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