Verbonac v. Canada (Attorney General)

canada, canadian, case law, court opinion, canlii, fct, 2026fc1135, 2026 fc 1135 (canlii), 2026, fc, 1135, (canlii), t-5064-25, 2026, taxation, tax free savings account, excess contributions tax, assessment of 1% monthly tax on highest excess amount, part xi.01 of the income tax act governs tfsa overcontributions, whether reassessment and excess contribution calculations were applied, education letter and notice of assessment referenced, application for judicial review dismissed, administrative law, judicial review, reasonableness, vavilov and mason “reasons first” approach, whether cra’s refusal to cancel tfsa excess contribution tax was unreasonable, transparency, intelligibility and justification assessed, applicant’s burden to show central flaws, reasonableness standard applied, application dismissed, taxation, ministerial discretion, income tax act, subs. 207.06(1), cancellation of tfsa overcontribution tax, whether tax liability arose from a “reasonable error” and excess amounts were removed “without delay”, conjunctive conditions confirmed, messenger v canada (attorney general), “without delay” treated as within 30 days, posmyk v canada (attorney general), relief refused, procedure, judicial review record, admissibility of evidence, certified tribunal record, whether a post, dating, undated letter not in the record could be considered, general rule limiting evidence to what was before the decision, maker, tsleil, waututh nation v canada (attorney general), exceptions not established, letter given no weight, application dismissed