A number of commentators, including Justice John Owen, have expressed unease with the reasoning of the Federal Court of Appeal in R v Paletta (Estate), 2022 FCA 86, and Brown v R, 2022 FCA 200. They might say “I told…
Source of income and the normal reassessment period
In Boles v R, 2024 TCC 167, the taxpayers incurred losses in respect of “Dog Activities” (breeding and selling purebred dogs and attending dog shows) and some rental properties. The Court concluded the CRA could not reassess statute-barred years for…