Subsection 244(14.1) of the Income Tax Act creates a presumption that a taxpayer has received a notice of assessment or reassessment on the day the CRA sends an email notifying the taxpayer that a document has been posted to the taxpayer’s online account. To date, the courts have found that a taxpayer did receive a notice even though the taxpayer claimed not to have. The authors point out that subsection 244(14.1) creates a rebuttable presumption and not a deeming rule. The authors hope the courts, in future, will give more weight to the distinction in deciding like cases.
David Sherman and Balaji (Bal) Katlai “What Happens If You Don’t See Your CRA Email?” Tax for the Owner-Manager 26:3 (July 2026)
