Bozzer v. Canada, 2011 DTC 5106 [at at 5922], 2011 FCA 186 -- summary under Vested Rights

In finding that an ambiguity in the interpretation of s. 220(3.1) should be resolved in a manner that did not take away a right of the taxpayer to apply for relief from accrued interest on an assessment, Stratas J.A. stated (at para. 41) that "it was incumbent on Parliament to be clear in its language imposing the restriction and any doubt should be resolved in favour of the taxpayer; and further quoted with approval the statement in Morguard Properties Ltd v. City of Winnipeg, [1983] 2 SCR 493 at 509 that "the courts require that, in order to adversely affect a citizen's right, whether as a taxpayer or otherwise, the legislature must do so expressly."