The case Ontario Addictions Treatment Centre and The Attorney General of Canada is the objective answer to the question of whether one should file a rebate or appeal application when the CRA’s position is still being debated. There was no downside to filing the rebate application while waiting for CRA to come up with a position and it’s surprising that with all the brainpower that was deployed for this ruling request, that no one thought of making the rebate claim while waiting for the answer. Don’t let that be your mistake. Talk to a ZheroTax expert about your rebate application or appeal and get it filed within the statutory timelines.