Introduction to the Relevant Law on TFSA Over-Contribution and
Non-Resident Contribution
Before discussing the case of
Ifi v. Canada (Attorney
General), 2020 FC 1150, an introduction to the underlying law
is necessary to provide context. Tax-Free Savings Accounts (TFSAs) are popular
savings and investment tools for Canadians. A taxpayer contributes
to his or her TFSA using his or her after-tax income for the year.
The funds within the TFSA are then generally invested to earn
additional income within the TFSA. Funds are withdrawn from the
TFSA tax-free, allowing individuals to earn tax-free income.
Individuals who have TFSAs can be subject to two different