Judicial review in the Federal Court of Canada is the procedural route for challenging certain Canada Revenue Agency decisions that are not directly disputable through the objection and Tax Court process — for example, the denial of taxpayer relief, the rejection of a voluntary disclosure, or certain discretionary or procedural decisions.
The Court does not redetermine the tax itself. It reviews whether the decision was reasonable, meaning whether it falls within a range of acceptable outcomes given the facts and the law. If the decision is found unreasonable, the usual remedy is to send the matter back to the CRA for redetermination rather than to substitute the Court's own decision. The application generally must be brought within 30 days of the decision, subject to extension.