Before ordering that the respondent be changed from the CRA to the Attorney General of Canada (AGC), Southcott J stated (at paras. 24-25):
As the Respondent submits, Rules 303(1) and (2) of the Federal Courts Rules … provide that, where an application does not directly affect another person other than a tribunal in respect of which the application is brought, the application shall name the AGC as a respondent. As CRA is effectively the tribunal in respect of which the application is brought, the Respondent takes the position that the appropriate respondent is the AGC.
… I agree with the Respondent’s analysis … .