I don't know the filing fees or anything, but there's a cap on the amount of dollars at issue if you're going under the informal procedure and if you go general procedure you have to have a lawyer and the process is more complex and expensive. The thing is, either way, it takes a long time and the penalties and interest are adding up. If you lose, it's gonna sting.
Where an issue is worth tens of millions of dollars and you have lawyers saying CRA's position is wrong and a court would not agree with them, you're probably okay filing on a basis contrary to CRA's assessing policy and gearing up for a long, drawn out fight. But in this guy's case, it's probably not cost-effective.
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