Federal Court of Appeal Upholds Denial of Benefits Due to Insufficient Income
📌 In brief
The Federal Court of Appeal upheld the denial of the Canada Recovery Benefit and the Canada Worker Lockdown Benefit to a claimant due to insufficient income. The Court relied on the claimant's income tax returns and found the denial process to be procedurally fair.
⚖️ Legal holding
A claimant's eligibility for benefits under the CRB and CWLB is determined based on reasonable interpretation of submitted documentation, including income tax returns.
📖 Technical summary
The Federal Court of Appeal dismissed the appeal, affirming the denial of benefits due to insufficient income.
📜 Headnote Official document
The Federal Court of Appeal dismissed an appeal challenging the denial of the Canada Recovery Benefit and the Canada Worker Lockdown Benefit due to insufficient income. The Court affirmed the reasonableness of the decision based on the claimant's income tax returns and procedural fairness.
📚 Full judgment Official document
Date: 20260323 Docket: A-95-25 Citation: 2026 FCA 61 CORAM: LASKIN J.A. [NAME] J.A. WALKER J.A. BETWEEN: [NAME] Appellant and ATTORNEY GENERAL OF CANADA Respondent Heard at Toronto, Ontario, on March 23, 2026. Judgment delivered from the Bench at Toronto, Ontario, on March 23, 2026.
REASONS FOR
JUDGMENT OF THE COURT BY: [NAME] J.A. Date: 20260323 Docket: A-95-25 Citation: 2026 FCA 61 CORAM: LASKIN J.A. [NAME] J.A. WALKER J.A. BETWEEN: [NAME] Appellant and ATTORNEY GENERAL OF CANADA Respondent
REASONS FOR
JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on March 23, 2026). [NAME] J.A. [ 1 ] [NAME] appeals a decision of the Federal Court (2025 FC 252) that dismissed his applications for judicial review of two decisions of an Officer of the Canada Revenue Agency (CRA). Those decisions found [NAME] ineligible for the Canada Recovery Benefit (CRB) and the Canada Worker Lockdown Benefit (CWLB), concluding that he had not met the minimum income requirements for these benefits. [ 2 ] [NAME] raises three issues in his appeal. First, he argues that the Federal Court erred in excluding his affidavit dated August 1, 2024 on the grounds both that it was submitted late and that it contained information that was not before [NAME] when making the impugned decisions. Second, [NAME] argues that [NAME]’s conclusion that he had not met the minimum income requirements was flawed. Finally, [NAME] argues that it was procedurally unfair to deny him the CRB and CWLB after having given him those benefits for a period of time without sufficient warning of the consequences of a later finding of ineligibility. [ 3 ] It is our view that [NAME] cannot succeed on any of these issues. [ 4 ] [NAME] argues that the cited grounds for excluding his August 1, 2024 affidavit were erroneous in that (i) an extension of time was granted by Associate Judge John C. Cotter, and hence it was not submitted late, and (ii) the affidavit reiterates information that was before [NAME] when making her decisions, and hence he cannot be accused of introducing new evidence. [ 5 ] In fact, the extension of time concerned the deadline for filing [NAME]’s application record pursuant to Rule 309 of the Federal Courts Rules , S.O.R./98-106. It was not permission to include in that application record an affidavit that had not previously been duly served as provided for in Rule 306. Therefore, the Federal Court was correct to exclude [NAME]’s August 1, 2024 affidavit on the basis that it was submitted late. [ 6 ] [NAME]’s argument that the affidavit simply reiterates information that was already before [NAME] is not convincing since this simply highlights the fact that the information is already on file and the affidavit is not necessary. [NAME] has not indicated specifically how his argument at the Federal Court was impaired by the exclusion of his affidavit. [ 7 ] The merits of [NAME]’s decisions are to be reviewed based on their reasonableness. We step into the shoes of the Federal Court and focus on those decisions: [NAME] v. Canada (Minister of Public Safety and Emergency Preparedness) , 2013 SCC 36, [2013] 2 S.C.R. 559 at paras. 45-46. [NAME] criticizes [NAME]’s emphasis on his income tax return, arguing that it is inconclusive proof of his actual income. While we agree that income tax returns are not conclusive proof of income for the purposes of the CRB and the CWLB, they are relevant to the issue, and we find nothing unreasonable in [NAME]’s reference to [NAME]’s income tax return in making the impugned decisions. [NAME] did not indicate that she felt bound by [NAME]’s return. [ 8 ] [NAME] argues that he had no expenses for the purposes of eligibility for the CRB and the CWLB. He argues that [NAME] determined that his net income was insufficient by applying expenses carried forward from previous years. He argues that it was unreasonable for [NAME] to have determined his eligibility for the CRB and the CWLB on this basis. We are not convinced that [NAME] acted unreasonably in this regard. [ 9 ] Turning now to the issue of procedural fairness, it is important to bear in mind that it concerns procedure and cannot give rise to substantive rights. The ultimate question on this issue is whether [NAME] knew the case he had to meet, had an opportunity to respond and had an impartial decision maker consider his case fully and fairly: Canadian Pacific Railway Company v. Canada (Attorney General) , 2018 FCA 69, [2019] 1 F.C.R. 121 at para. 41. [ 10 ] These requirements are met in this case. [NAME]’s argument on this point essentially seeks a substantive right to keep benefits to which [NAME] reasonably concluded he was not entitled. His argument that he would have had to be represented by a lawyer to successfully challenge the impugned decisions does not alter the reasonableness of that conclusion, nor does it demonstrate that he was unaware of the case he had to meet or was denied an opportunity to respond. [ 11 ] For the foregoing reasons, we will dismiss this appeal with costs fixed in the all-inclusive amount of $250. "[NAME]" J.A. FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-95-25 STYLE OF CAUSE: [NAME] v. ATTORNEY GENERAL OF CANADA PLACE OF HEARING: TORONTO, ONTARIO DATE OF HEARING: March 23, 2026
REASONS FOR
JUDGMENT OF THE COURT BY: LASKIN J.A. [NAME] J.A. WALKER J.A. DELIVERED FROM THE BENCH BY: [NAME] J.A. APPEARANCES : [NAME] For The Appellant ON HIS [NAME] For The Respondent SOLICITORS OF RECORD : [NAME] of Canada For The Respondent
⚖️ What tends to weigh in cases like this
✅ Tends to be accepted
- The court found it reasonable for the CRA officer to rely on income tax returns to determine eligibility for benefits.
- The court considered it appropriate that the appellant had no new evidence beyond what was already on file.
- The court maintained that procedural fairness was upheld as the appellant was aware of the case he had to meet and had an opportunity to respond.
❌ Tends to be rejected
- The court dismissed the argument that the affidavit submitted late should have been included despite an earlier extension being for a different purpose.
- The court rejected the argument that the CRA officer unreasonably used carried-forward expenses to determine the appellant's net income.
- The court did not accept the argument that the appellant had a substantive right to keep benefits he was reasonably deemed ineligible for.
Patterns observed in similar cases in this collection — every case is unique.
❓ Frequently asked questions
What did this decision decide?
The Federal Court of Appeal decided to uphold the denial of the Canada Recovery Benefit and the Canada Worker Lockdown Benefit to the claimant due to insufficient income.
What was the dispute about?
The dispute was about whether the claimant met the income eligibility criteria for the Canada Recovery Benefit and the Canada Worker Lockdown Benefit.
How did the court decide, and why?
The court decided that the claimant did not meet the income eligibility criteria based on the reasonable interpretation of the claimant's income tax returns.
Which laws or rules were applied?
No specific laws or rules were applied in this decision.
What was the argument that mattered most?
The argument that mattered most was the claimant's contention that the denial was procedurally unfair and that the income tax returns were not conclusive proof of income.
Was the decision for or against the person who brought the case?
The decision was against the person who brought the case.
What does this mean for someone in a similar situation?
Someone in a similar situation should ensure that their income documentation accurately reflects their income to meet eligibility criteria for benefits.
What evidence or documents mattered?
The claimant's income tax returns were the primary evidence considered in the decision.