[22] The CRA also submits that any issues relating to whether Mr. McCartie owes a GST debt, falls within the jurisdiction of the Tax Court of Canada and says that Mr. McCartie’s allegation that the CRA does not have the constitutional authority to register his GST account is a disguised attack on the validity of the GST debt. The owing of GST, it says, is by operation of the ETA and the registration of the GST number is just an administrative process.
[29] [The Federal Court] has held that “[CRA] is empowered to assign a GST number and assess an individual, whether or not that individual has voluntarily applied for a GST number” and that any attack on that assignment is a collateral attack on the GST assessment which is exclusively within the jurisdiction of the Tax Court of Canada: Lewry v Canada (The Minister of National Revenue), Court File T-1430-11, Order dated December 23, 2011.