John Sorensen, “Credibility and an Assessment’s Mailing”, Canadian Tax Highlights 25:1 (January 2017) comments on Mpamugo (2016 TCC 215). The case summarizes four steps for dealing with disputes over whether and when a notice was mailed: The taxpayer must assert…
Normal reassessment period
Hall v R, 2016 TCC 221, addresses the normal reassessment period for tax payable under a Part of the Income Tax Act (Canada). The case confirms that the period does not begin until an initial assessment is issued under that…
What is a nil assessment?
In Shreedhar v R, 2016 TCC 254, the Crown brought a motion to strike an informal procedure appeal. The Crown claimed that the taxpayer was attempting to appeal from a nil assessment. The Court disagreed because, while the assessment had…
Assessing beyond
Assume that a taxpayer did not make a negligent misrepresentation in a year and that the year is beyond the normal reassessment period. Are the transactions undertaken in that year subject to further review by the CRA?
A notice of additional assessment
684761 BC Ltd v R, 2015 TCC 288, introduced me to the concept of the “additional assessment”. The CRA reassessed the taxpayer for its 2008 taxation year on December 16, 2011, just before the end of the relevant normal reassessment…