Judicial review
As a general rule, you should ask the Canada Revenue Agency (CRA) for a second administrative review before you file an application for judicial review with the Federal Court.
If you believe the CRA did not properly exercise its discretion in arriving at the decision, you can apply for judicial review of that decision to the Federal Court within 30 days of the date you received the CRA decision.
To apply for judicial review, you must send a completed Form 301, Notice of Application (Federal Court Web site), with the appropriate filing fee to the registrar of the Federal Court. For more information about how to file an application for judicial review or other general enquiries, visit the Federal Court website.
If it is determined that the Minister's discretion was not properly exercised, the Federal Court cannot change the CRA's decision but it can refer the decision back to the CRA to be reconsidered by another delegated official.