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The holiday season offers a rare opportunity for family members to come together to discuss important issues, including the often uncomfortable topic of estate planning
In the federal tax system, where a taxpayer has an outstanding tax debt in respect of which the Canada Revenue Agency ("CRA ") is permitted to commence collection actions, one of the steps that the CRA may take is to have a certificate registered in Federal Court (see for example, under subsection 233(3) of the Income Tax Act (Canada) or subsection 316(2) of the Excise Tax Act (Canada
