“The application of the principles of restitution/unjust enrichment to overpayments of tax in Canada is in a muddled state. The problem arises where a taxpayer overpays on the basis of a mistake of law or a mistake of fact, a capacious set of categories which can include mistakes about the lawfulness or applicability of a statute, regulation or administrative decision. The best place to start is with a couple of clear-eyed views of the problem …” (more)
[Paul Daly, 14 April]
First posted 2022-04-15 10:00:56
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