Ngoy – Quebec Court of Appeal allows a tax appeal on the basis of inadequate reasons

The taxpayers' appeal was allowed, and the matter was referred back to the Court of Quebec for a fresh adjudication, given that, in the appealed decision, the judge had not addressed the issue before her in her reasons for judgment (namely, whether the ARQ was justified in using the indirect cash flow method to arrive at its assessments of the taxpayer) otherwise than to quote the ARQ pleadings at length.

Neal Armstrong. Summary of Ngoy v. Agence du revenu du Québec, 2026 QCCA 193 under Federal Courts Act, s. 27(1.3).