Business · Companies · 3 hrs ago
Terry Hui’s companies accuse CRA of misconduct in tax debt dispute
Five companies linked to B.C. developer Terry Hui accuse the CRA of misconduct in a dispute over tax debts.
The companies say the government is wrongfully pursuing nearly $330 million, most of it interest.
The debts stem from an audit launched in 2013 that examined transactions involving Canada’s tax treaty with Luxembourg.
The group says it is developing projects in Toronto, Vancouver and Calgary, and that a large payment could take money away from active developments.
The companies want the Federal Court to halt collection until a related case is decided and object to a proposed $115 million security payment from one company.
The dispute follows a 2021 Supreme Court decision that upheld a tax exemption in a separate case involving the same treaty, but the companies’ current court applications have not yet been resolved.
Companies controlled by Terry Hui allege that the Canada Revenue Agency has acted improperly while seeking nearly $330 million in tax debts.
Five companies in Hui’s real estate development group are targeted in the CRA audit, including Adex Securities and two Luxembourg-based companies.
The companies filed an application in Federal Court this month, asking it to halt collection until a related case is concluded.
They say Adex faces a $115 million security demand and that paying it would divert capital from active development projects.
The CRA did not provide a spokesperson for an interview about tax treaty abuse.
- Who
- Five companies controlled by B.C. property developer Terry Hui, and the Canada Revenue Agency.
- What
- The companies challenge the CRA’s efforts to collect nearly $330 million in tax debts and allege a pattern of misconduct.
- When
- The companies filed an application in Federal Court in October 2026. The audit began in 2013.
- Where
- The application was filed in Federal Court in Canada. The companies’ projects include Toronto, Vancouver and Calgary.
- Why
- The companies want collection stopped until a related case is concluded and object to a $115 million security demand for Adex.
Hui’s companies
Canada Revenue Agency
Collection of the debts
Hui’s companies
The companies say the government has wrongfully moved to collect nearly $330 million and ask the court to stop collection for now.
Canada Revenue Agency
The CRA is seeking to collect the debts and wants Adex to provide $115 million in security; its rationale is not stated.
Conduct in the dispute
Hui’s companies
The companies allege CRA officers acted outside established policies and without regard to effects on taxpayer businesses.
Canada Revenue Agency
The CRA did not provide a spokesperson for an interview about tax treaty abuse.
The tax debts at issue date back as far as this year.
The CRA audit began, focusing on transactions that relied on Canada’s tax treaty with Luxembourg.
A related case was filed.
The companies received tax debt assessments, according to their court application.
The companies filed an application in Federal Court seeking to stop collection while the related case is concluded.
- Total debts
- Nearly $330 million, most of it accrued interest
- Companies targeted
- Five, including Adex Securities, One West Holdings and two Luxembourg-based shell companies
- Adex assessment
- $45 million in tax and more than $65 million in interest
- Luxembourg-based companies’ assessments
- More than $92 million in tax and $127 million in interest together
- Security sought from Adex
- $115 million
- Projects cited
- Toronto, Vancouver and Calgary
2 sources
What people are saying
pattern of misconduct
lose significant capital that is currently being used to fund active development projects.
could not have reasonably planned for a debt … of this magnitude.
the court should not legitimize such blatantly abusive tax avoidance based on the view that Canada should have negotiated different treaty terms.