By David J. Rotfleisch ( October 21, 2025, 1:05 PM EDT) -- In Hutchings v. Canada, 2025 TCC 108, the Tax Court of Canada reaffirmed a core statutory principle: in the context of the Canada Emergency Rent Subsidy (CERS), rent must be “paid under a written lease” to qualify. Even long-standing verbal arrangements, supported by consistent rent payments, were held insufficient to satisfy the strict requirements of the Income Tax Act. That ruling offers a vital lesson for tax lawyers, corporate counsel and real-estate stakeholders: compliance with technical formality requirements can prove determinative in government relief litigation....