The appellant corporation brought a motion seeking leave to be represented by its sole director and officer in a General Procedure tax appeal.
The Tax Court of Canada dismissed the motion, holding that under subsection 17.1(1) of the Tax Court of Canada Act and subsection 30(2) of the Tax Court of Canada Rules (General Procedure), a corporation must be represented by counsel.
The court also applied the common law factors for corporate representation, finding that the proposed representative would have difficulty marshalling evidence for an indirect audit methodology and applying complex tax law.
The appellant was ordered to retain counsel.
