In general, the CRA cannot collect a debt under the Income Tax Act (Canada) where the tax debtor has objected to, or appealed from, the reassessment underlying the debt (section 225.1). In Canada (National Revenue) v Zhao, 2022 FC 1108, however, the Court granted a jeopardy collection order permitting the CRA to collect a tax debt that was under objection. The taxpayer had left the country owing a significant amount of tax, he appeared to have no intention of returning and he was in the process of selling his only Canadian asset (a home).
