- Parties: The appellant was the Ontario Addiction Treatment Centres. The respondent was the Attorney General of Canada.

- Subject Matter: The appellant filed a judicial review application challenging a decision of the Minister of National Revenue. The Federal Court dismissed the appellant’s application and refused its request for remission of tax under s. 23(2) of the Financial Administration Act, 1985. The appellant challenged the Federal Court’s judgment.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal with costs. The appeal court held that the Federal Court correctly identified reasonableness as the standard of review, properly applied it, and gave proper reasons supporting those conclusions. The appeal court found no incorrect action on the Canada Revenue Agency’s part that caused a payment or retention of tax that was unreasonable, unjust, or against the public interest in the circumstances. The appeal court disagreed with the appellant’s argument that the decision failed to provide sufficient justification for the outcome reached. There was a coherent and rational chain of reasoning between the evidence and the outcome reached, the appeal court found. Lastly, the appeal court agreed with the Federal Court’s reasons and conclusion on the issue of procedural fairness.

- Date: The hearing was set on Dec. 4, 2023. The court released its decision on Dec. 4, 2023.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: No financial award was specified.