Case Details:

1. Claims Against CRA: The Plaintiffs alleged damages due to CRA's actions in collecting an income tax debt. They claimed breach of statutory, constitutional, and common law duties, negligence, harassment, breach of confidentiality, and vicarious liability for CRA employees' actions.

2. CRA's Reassessment: In 2007, CRA reassessed Ms. Ferreira's taxes for 2005 and 2006, resulting in a tax debt due to missing T4 slips. Despite several communications and reassessments, the debt was not resolved until 2019, when the correct T4 information was provided, leading to debt reversal.

3. Lien and Property Sale: CRA registered a lien on the Plaintiffs' property in 2018 due to the outstanding tax debt, affecting their mortgage refinancing. The property was sold in 2020, after the lien was discharged.

Key Legal Points:

• Limitation Period: The CRA argued the action was filed beyond the two-year limitation period under the Ontario Limitations Act.
• Jurisdiction and Tax Assessments: The CRA contended that challenges to tax assessments must be made in Tax Court, not Federal Court.
• Negligence and Constitutional Rights: Plaintiffs' claims of negligence, breach of constitutional rights, and breach of trust were examined.

Court's Analysis and Decision:

• Limitation Period: The Court agreed with CRA, finding the action was filed outside the limitation period.
• Jurisdiction: The Federal Court lacks jurisdiction over tax assessments; such issues belong in the Tax Court.
• Claims Analysis: The Court found no evidence to support the Plaintiffs' claims of negligence, constitutional rights breach, or breach of trust.

Conclusion:

• The Federal Court granted CRA's motion for summary judgment, dismissing the action in its entirety. Costs were awarded to the Defendant.