PwC’s Submissions on Proposals to Improve the Caseload Management of the Tax Court of Canada

In this submission, PwC Canada responds to a request for proposals to improve the caseload management of the Tax Court of Canada. PwC expresses its support for the Department of Finance's initiative to improve the caseload management of the Tax Court of Canada, but cautions that further guidance is needed to determine when the court should hear a question arising out of identical or substantially similar transactions and cause the resulting judicial determination to be binding across a group of taxpayers. Importantly, we also make suggestions to improve the current audit process so that fewer tax disputes need to be referred to the courts for resolution.