Laplante, a self-employed singer and vocal teacher, lost her income sources due to the COVID-19 pandemic and received the Canada Recovery Benefit (CRB).
The Canada Revenue Agency (CRA) later determined she was not eligible for CRB because she didn't meet the $5,000 net income requirement in 2019, 2020, or in the 12 months preceding her application. CRA’s assessment showed her net business income had been negative or below $5,000 since 2016.
Laplante argued that the decision was unreasonable, citing a proposal by her accountant to amend her 2020 tax return retroactively, which would increase her income above $5,000, making her eligible for CRB.
Legal Issues:
CRB Eligibility: Assessment of the reasonableness of CRA's decision in denying Laplante’s CRB eligibility.
Income Calculation and Retroactive Tax Amendment: Whether Laplante could amend her tax return retroactively to meet CRB income requirements.
Judgment:
Judge: Vanessa Rochester
Decision: Judicial review application rejected.
Reasoning:
The Court found the CRA's decision reasonable. Laplante's income for the relevant years was either negative or below the $5,000 threshold.
The Court did not accept the argument for retroactive amendment of the tax return, aligning with principles against retroactive tax planning.
The decision was justified, intelligible, and transparent, meeting the criteria set in jurisprudence.
Conclusion:
The Federal Court upheld the CRA's decision, emphasizing the importance of meeting statutory income criteria for benefit eligibility and rejecting the notion of retroactive tax amendment as a means to qualify for government benefits. The decision stresses adherence to established tax law principles.
