On April 10, 1990, the House of Commons passed the Goods and Services Tax bill by 144 to 114 votes ending a bitter dispute that lasted for 9 months. The bill, opposed by 75 to 85% of Canadians, was to replace the hidden Manufacturers Sales Tax introduced in 1924. The bill was sent to the Senate for debate and the Liberals vowed to block the bill in the Senate. In October, 1990, Prime Minister Brian Mulroney used an obscure, never-before implemented section of the Constitution – section 26 of the Constitution Act, 1867, which allowed him to ask Queen Elizabeth II to approve the appointment of 8 extra senators. This political manoeuvre increased the number of senators from 104 to 112. By filling 15 vacant seats and getting the 8 extra seats, Mulroney managed to pack the Senate in his favour and pushed the bill through the Senate on a 55-49 vote in December 1990.
Prior to 1990, there was only one attempt to use section 26 of the Constitution Act. In 1873, Alexander Mackenzie requested the appointment of 6 extra senators but was refused by Queen Victoria. The Colonial Secretary, the Earl of Kimberley, decided that section 26 was to be used only when there was a collision of opinion between the two Houses of such a serious and permanent nature that it would paralyze or incapacitate the government.