Two appeals will be heard tomorrow morning by the Supreme Court
of Canada in rectification decisions from the Quebec courts. The
first appeal is Agence du Revenu du Québec (formerly the
Deputy Minister of Revenue of Quebec) v. Services Environnementaux
AES Inc., et al. while the second appeal is Agence du
Revenu du Québec v. Jean Riopel, et al. In each case,
the Quebec Court of Appeal agreed with the taxpayers that
rectification was in order.
The Supreme Court's summary of the first appeal may be found
here. Each factum in the first appeal may be
The Supreme Court's summary of the second appeal may be
found here. Each factum in the second appeal may be
The decision of the Quebec Court of Appeal in the first appeal
is here. The decision of the Quebec Court of
Appeal in the second appeal is here.
At 9:30 a.m. tomorrow, the live webcast of the hearings may be
viewed here or here. The archived webcast will be available
for viewing a day or two later.
The newest member of the Supreme Court of Canada, Justice Richard Wagner, was a member of the
panel of the Quebec Court of Appeal that decided the second appeal.
He will, therefore, not hear tomorrow's appeals. Accordingly, a
maximum of seven judges will be on the panel tomorrow morning.
We will publish a blog post by the end of the day tomorrow
reporting on the arguments in the Supreme Court of Canada.
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