Subsection 152(1) - Assessment
Cases
Rosenberg v. Canada (National Revenue), 2016 FC 1376
Following an audit of the straddle transactions engaged in by the taxpayer for his 2006 and 2007 taxation years, the CRA auditor drafted an...
AFD Petroleum Ltd. v. Canada (Attorney General), 2016 FC 547
The taxpayer filed its claim for SR&ED deductions in reliance on s. 37(11), which provided that the form can be filed up to 12 months after the...
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| Tax Topics - Income Tax Act - Section 37 - Subsection 37(11) | missing information in T661 on technological obstacles was substantive/no remedy if T661 rejected after objection period | 356 |
AgraCity Ltd v. Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288
A Barbados corporation reported substantial profits from the sale of a herbicide to Canadian farmers, and deducted amounts paid to a non-arm’s...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | boundary between ss. 247(2)(a) and (b) is unresolved/inconsistent assessments of related taxpayers | 389 |
| Tax Topics - Other Legislation - Federal - Tax Court Rules - Section 53 | inconsistent assessments of related taxpayers | 240 |
| Tax Topics - Other Legislation - Federal - Tax Court Rules - Section 82 | inconsistent assessments of related taxpayers | 307 |
McNally v. Canada (National Revenue), 2015 FC 767
The taxpayer participated in a leveraged donation arrangement and filed his return on a timely basis. Two months later, he received a CRA...
Canada v. Last, 2014 DTC 5077 [at 6998], 2014 FCA 129
At trial, the taxpayer argued that certain expenses should have been allowed in determining his rental income, and that his gain from the...
Ficek v. Canada (Attorney General), 2013 FC 502
The taxpayer participated in a software licence donation arrangement under a registered tax shelter ("GLGI"), in which the taxpayer would acquire...
Transalta Corporation v. Canada, 2013 FCA 285
The taxpayer established at the Tax Court that certain employee share bonuses were deductible after the Crown had already conceded that employee...
Armstrong v. Canada (Attorney General), 2006 DTC 6310, 2006 FCA 119
Sharlow J.A. noted (at p. 6311) that "an amended return for a taxation year that has already been the subject of a notice of assessment does not...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Res Judicata | 146 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.1) | 43 |
Canada v. Harris, 2000 DTC 6373 (FCA)
In dismissing an appeal by the Crown of a refusal to strike a statement of claim by a member of a public interest group alleging that, in granting...
Ginsberg v. Canada, 96 DTC 6372, [1996] 3 CTC 63 (FCA)
Failure of the Minister to assess the taxpayer with all due dispatch did not invalidate the assessments ultimately made.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | Minister's failure to act with all due dispatch is not a basis for vacating an assessment | 112 |
| Tax Topics - Income Tax Act - Section 166 | 45 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 11 | 45 |
Schatten v. MNR, 96 DTC 6102 (FCTD)
After finding that the non-residency of the applicant was not a ground for the Minister to refuse to process her income tax returns, Reed J....
Duthie Estate v. The Queen, 95 DTC 5376 (FCTD)
In finding that it would not have been inappropriate for the Minister to assess the taxpayer on the basis that he had disposed of personal-use...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Estoppel | 85 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 49 | |
| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) | change of use when project manager retained | 128 |
The Queen v. Guaranty Properties Ltd., 90 DTC 6363 (FCA)
An amalgamation of two corporations under the laws of Ontario did not cause the amalgamated corporations to cease to exist for purposes of their...
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| Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) | 205 |
The Queen v. Riendeau, 90 DTC 6076 (FCTD), aff'd 91 DTC 5416 (FCA)
Before finding that reassessments of the Minister were not invalid because they were based on a repealed provision of the Act (s.74(5)), rather...
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | 125 |
The Queen v. W.H. Violette Ltd., 88 DTC 6025, [1988] 1 CTC (FCTD)
Since "each taxation year must be considered independently ... it is difficult, if not impossible, to conceive how a reassessment for one taxation...
Interprovincial Steel and Pipe Corp. v. The Queen, 86 DTC 6583, [1986] 2 CTC 473 (FCA)
The Minister cannot use his power of assessment to collect sums that are not exigible under the Act (even though he might be entitled to those...
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| Tax Topics - Income Tax Act - Section 164 - Subsection 164(3.1) | 21 |
The Queen v. Consumers' Gas Co. Ltd., 87 DTC 5008, [1987] 1 CTC 79, 87 DTC 5008 (FCA)
It was indicated, obiter, that the Minister was not precluded from taking a position before the trial division that was inconsistent with the...
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| Tax Topics - General Concepts - Accounting Principles | 35 | |
| Tax Topics - Income Tax Act - Section 181 - Subsection 181(3) | 78 |
Lipsey v. MNR, 85 DTC 5080, [1984] CTC 675 (FCTD)
Strayer, J., doubted that a judge would ever be in a position to direct the issuance of a notice of assessment because "to issue mandamus the...
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|---|---|---|
| Tax Topics - Other Legislation - Federal - Federal Court Rules - Rule 1211(1) | 19 | |
| Tax Topics - Other Legislation - Federal - Federal Court Rules - Rule 355(4) | 30 |
Sedgewick Co-operative Association Ltd. v. The Queen, 83 DTC 5455, [1984] CTC 14 (FCTD)
"[I]f the Minister has admitted through the assessment that certain facts exist, he cannot later withdraw that admission." However, as was the...
Cohen v. The Queen, 80 DTC 6250, [1980] CTC 318, 80 DTC 6250 (FCA)
The Minister has a statutory duty to assess the amount of tax payable on the facts as he finds them in accordance with the law as he understands...
Brown v. The Queen, 79 DTC 5421, [1979] CTC 476 (FCTD)
It was suggested that it was "an unwarranted interference by the Minister in the conduct of the affairs of [a] trust by the trustee", where, out...
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|---|---|---|
| Tax Topics - General Concepts - Estoppel | 78 | |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | 42 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 45 |
Hutterian Brethren Church of Wilson v. The Queen, 79 DTC 5052, [1979] CTC 1, 79 DTC 5052 (FCTD), aff'd 79 DTC 5474, [1980] CTC 1 (FCA)
It was reasonable for the Minister to delay assessing incorporated Hutterian colonies pending the disposition of an appeal process concerning the...
Rodman Construction Inc. v. The Queen, 75 DTC 5038, [1975] CTC 73 (FCTD)
The non-resident taxpayer received payments on a non-interest bearing mortgage between 1964 and 1969 after showing the deed to a Revenue Canada...
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| Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) | not applicable where purchase price at FMV | 101 |
Galway v. M.N.R., 74 DTC 6355, [1974] C.T.C. 454 (FCA)
After a finding at trial that a $200,500 amount was includible in the taxpayer's income, the Court of Appeal lacked the jurisdiction to grant a...
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| Tax Topics - Income Tax Act - Section 177 - Subparagraph 177(b)(iv) | 149 |
Western Minerals Ltd. v. Minister of National Revenue, 62 DTC 1163, [1962] CTC 270, [1962] S.C.R. 592
The Minister initially assessed the taxpayer for the amount shown as payable in its return and subsequently reassessed for additional tax plus...
See Also
Sood v. Canada (National Revenue), 2015 FC 857
The applicant objected to the denial of his claim to the Ontario new housing rebate, and he then accepted a CRA offer to refund the difference...
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| Tax Topics - Excise Tax Act - Section 296 - Subsection 296(1) | settlement agreement not according with law required to be revoked | 179 |
| Tax Topics - Other Legislation - Federal - Federal Court Act - Section 18.5 | requested enforcement of settlement agreement was collateral attack on assessment | 160 |
Wesdome Gold Mines Ltd. v. ARQ, 2014 QCCQ 8444
Assessments made by the ARQ of the taxpayer for its 2006 and 2007 taxation years, after it had been dissolved in connection with voluntary...
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| Tax Topics - Other Legislation - Quebec - Business Corporations Act - Section 313 | parent of dissolved corporation should have been assessed for its taxes | 81 |
Bolton Steel Tube Co. Ltd. v. The Queen, 2014 DTC 1102 [at 3202], 2014 TCC 94
In 2007 the Minister reassessed the 1994 to 1997 taxation years of the taxpayer ("Bolton"). For 1996, the Minister added $602,998 in alleged...
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| Tax Topics - General Concepts - Evidence | terms of agreement established with regard to "factual matrix" | 116 |
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) | s. 169(3) reassessment cannot increase quantum of previous assessment | 210 |
Gallant v. The Queen, 2012 DTC 1140 [at 3233], 2012 TCC 119 (Informal Procedure)
Woods J. found that the Crown was not estopped from applying s. 118.61(4) to reduce the taxpayer's unused tuition, textbook and education tax...
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| Tax Topics - Income Tax Act - Section 118.61 | 105 |
R (Davies) v. Revenue and Customs Commissioners, [2012] 1 All ER 1048, [2011] UKSC 47
The taxpayers submitted that the court should give effect to their legitimate expectation that the test as to individual residency contained in...
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| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | 497 |
Cooper v. The Queen, 2009 DTC 800, 2009 TCC 236 (Informal Procedure)
The Court had the jurisdiction to consider the computation of the payment of interest on refunds payable under the Act to the taxpayer in...
Kruco Inc. v. The Queen, 2001 DTC 668 (TCC), aff'd 2003 FCA 284
Dussault T.C.J. indicated (at p. 690) that accepting the administrative policy of the Minister in that case respecting the computation of safe...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | safe income | 72 |
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) | phantom income position rejected | 210 |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 81 |
Mierins v. The Queen, 96 DTC 1140 (TCC)
Bonner TCJ. found that the "with all due dispatch" requirement contained in s. 152(1) applied only to the initial examination of the taxpayer's...
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(ii) | 81 |
D'Amico v. The Queen, 95 DTC 622 (TCC)
The taxpayers, along with numerous other individuals, had in their 1986 taxation years, purchased interest in limited partnerships whose units...
Taylor v. The Queen, 95 DTC 591 (TCC)
Before going on to find that the Minister could not be estopped from assessing the taxpayer for interest and penalties properly payable by the...
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| Tax Topics - General Concepts - Estoppel | 29 |
Ginsberg v. The Queen, 94 DTC 430 (TCC), rev'd supra.
Before finding that a delay of one and one-half years in assessing the taxpayer's return did not satisfy the "with all due dispatch" requirement...
Van Leenen v. MNR, 91 DTC 1265 (TCC)
In dealing with a submission that a Revenue Canada official had given the taxpayer some assurance that the taxpayer would not be assessed under s....
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| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) | 89 |
McConnachie v. MNR, 91 DTC 873 (TCC)
Bonner TCJ. questioned the validity of purported notices of assessment of the taxpayer (under section 227.1) which were uninformative and somewhat...
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| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) | 107 |
Leung v. MNR, 91 DTC 1020 (TCC)
In vacating an assessment of the taxpayer pursuant to s. 227.1 of the Act and corresponding provisions of the Income Tax Act (Ontario), the...
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | 25 |
Inland Revenue Commissioners v. Nuttall, [1990] BTC 107 (C.A.)
In finding that the Inland Revenue had the power to compromise claims for back duty where no assessment had been mailed and appealed against,...
B.M. Enterprises Ltd. v. MNR, 90 DTC 1037 (TCC)
An assessment issued pursuant to s. 227(10) by a supervisor within a collections branch was invalid, as the individual was not one of the...
R. v. I.R. Commrs., ex parte MFK Underwriting Agencies Ltd., [1989] BTC 561 (D.C.)
Inland Revenue correspondence respecting whether the uplift on redemption of certain U.S.-dollar index-linked bonds would be taxable on income...
J. Stollar Construction Ltd. v. MNR, 89 DTC 134 (TCC)
An original assessment which was made more than six years after the mailing by the taxpayer of its return was vacated in the absence of any...
R. v. IRC Ex parte Preston, [1985] BTC 208 (HL)
Lord Templeman stated: "that the Commissioners are guilty of 'unfairness' amounting to an abuse of power if by taking [special assessment] action...
Air Canada v. Turner, [1984] 6 WWR 346 (BCSC)
When the Legislature imposes a tax, it is the duty of the authorized officer (subject to administrative common sense) to assess that tax upon all...
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| Tax Topics - Income Tax Act - Section 221 - Subsection 221(1) - Paragraph 221(1)(f) | 105 |
Administrative Policy
11 August 2015 External T.I. 2014-0527291E5 F - Remboursement de frais médicaux-CIMAD
After finding that the reversal by 2013-0490901I7 of 2001-0113237 (respecting the Ontario Healthy Homes Renovation Tax Credit) also applied to the...
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| Tax Topics - Income Tax Act - Section 118.2 - Subsection 118.2(3) - Paragraph 118.2(3)(b) | Quebec Tax Credit for Home-Support Services for Seniors does not reduce METC | 220 |
11 April 2016 CRA Press Release “Government of Canada cracks down on tax evasion”
[T]he Government of Canada will invest over $444 million to enhance the Canada Revenue Agency’s (CRA) ability to detect, audit, and prosecute...
8 March 2016 CRA Press Release
Recent media coverage has focused on the Canada Revenue Agency's (CRA) actions to address aggressive tax avoidance and offshore tax evasion,...
9 October 2015 APFF Roundtable Q. 25, 2015-0598321C6 F - Omission of deducting a dividend under 112(1)
In response to the specific example of a corporation which discovered that it had failed to claim the intercorporate dividend deduction in a...
May 2014 Alberta CPA Roundtable, Plenary Q.2
What are the respective functions of the Legislative Application Section (LAS) and the ITRD? Is the full text of the applicable LAS technical...
Toronto Centre Canada Revenue Agency & Professionals Group Newsletter, Vol. 13
Issue 4, December 2014
…Pilot project: Pre-ruling consultations Framework
The Income Tax Rulings Directorate (ITRD) is offering…[t]he...
7 December 1999 External T.I. 1999-0006715
What is Revenue Canada's position in respect of the shareholder's rights to file a Notice of Objection where the corporation has been dissolved? ...
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| Tax Topics - Other Legislation - Ontario - Business Corporations Act - Section 242 | assessment of dissolved corp | 165 |
28 May 1998 Internal T.I. 7-981166
An assessment under each Part of the Act is regarded as a separate assessment notwithstanding that RC may use a single notice of assessment to...
11 August, 1995 Memorandum 951801 (C.T.O. "No Assessments and Loss Determinations")
The fact that a return is now statute-barred does not negate the taxpayer's entitlement to request a determination under 152 (1.1), nor does the...
88 C.R. - Q.73
An ideal referral to the Head Office should contain a statement of facts agreed to by the District Office and the taxpayer, and arguments of each...
86 C.R. - Q.34:
The "due dispatch" requirement leaves RC with discretion, as justified by the circumstances and reasons of good administration.
Articles
Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709:
Suggests that the phrase "liable to" can create a liability to tax; and that, in any event, the creation of liability to tax, viewed as merely an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 222 - Subsection 222(1) - Tax debt | 110 |
Joel A. Nitikman, "The Legal Nature of Revenue Canada's Advance Rulings", Tax Litigation, Vol. VI, L. 2, 1998, p. 379.
Subsection 152(1.11)
Administrative Policy
2015 Ruling 2015-0604051R3 - Internal Reorganization
CRA provided s. 55(3)(a) rulings conditional on the U.S. parents receiving, and waiving the right to object, to GAAR assessments to reduce outside...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(iii) | note resulting from share redemption required to be vapourized on amalgamation/GAAR assessment required to reduce outside Canadian basis that US parents “paid for” by paying 5% Canadian withholding tax/rep re pubco share value being unaffected | 899 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.1) | pro-rata highly dilutive stock dividend | 117 |
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(2) | extensive reps required re series of transactions | 47 |
Subsection 152(1.1) - Determination of losses
Cases
Armstrong v. Canada (Attorney General), 2006 DTC 6310, 2006 FCA 119
S.152(1.1) did not cover the circumstances of the taxpayer's case because no non-capital loss initially was reported on his return for the...
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|---|---|---|
| Tax Topics - General Concepts - Res Judicata | 146 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | 82 |
Burnett v. MNR, 98 DTC 6205 (FCA)
More than four years after the initial assessment of her 1987 return, the taxpayer requested a determination of her non-capital loss for that year...
See Also
Aallcann Wood Suppliers Inc. v. The Queen, 94 DTC 1475 (TCC)
The Minister had not been correct in taking the position that because the taxpayer had not requested a loss determination for its 1988 taxation...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Contracts | 121 |
Administrative Policy
18 November 2014 TEI Roundtable, 2014-0550351C6 - 2014 TEI Liaison Meeting, Q.E1
After the questioner noted that "Finance would support an interpretation of subsection 152(1.1) that allowed a taxpayer to request that the amount...
27 November, 1995 T.I. 951977 (C.T.O "Notice of Determination of Losses")
In response to a query as to whether it was possible to utilize investment tax credits, once they had expired, by requesting a determination of...
11 August 1995 Memorandum 951801 (C.T.O. "Nil Assessments and Loss Determination")
There are no legislated time limits on a taxpayer's request for a loss determination under s. 152(1.1). No notification that no tax is payable is...
86 C.R. - Q.27
Requests should be made to the district office; and loss determinations will only be provided when the loss as filed by the taxpayer has been...
Articles
Shelley Griffiths, "'No discretion should be uncontrained'", ; Considering the 'care and management' of Taxes and the Settlement of Tax Disputes in New Zealand and the UK," [2012] British Tax Review, No. 2, p. 167, at 183:
"The care and management discretions of the UK and New Zealand revenue authorities are quite different, notwithstanding the fact that they are...
Subsection 152(1.2) - Provisions applicable
See Also
IncoLimited v. The Queen, 2004 TCC 373, aff'd 2005 DTC 5110, 2005 FCA 44
The taxpayer took the position that a letter of Revenue Canada indicating the amount of non-capital losses of the taxpayer for specified years,...
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|---|---|---|
| Tax Topics - Statutory Interpretation - Drafting Style | 87 |
Administrative Policy
6 March 2012 External T.I. 2011-0420751E5 - Ability to Object to a Denial of a Dividend Refund
S. 152(1.2) permits the filing of a notice of objection to the determination of a dividend refund under s. 129 even if the amount of such...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) | 29 |
Subsection 152(1.4) - Determination in respect of a partnership
Administrative Policy
23 April 2015 Internal T.I. 2014-0562271I7 - Amending a partnership return - limitation period
Will CRA accept an amended partnership return after the statute-barred date (where no waiver was produced within the three-year determination...
Articles
Anthony V. Strawson, "Should Partnership Information Returns be Filed as a Matter of Course?", Tax for the Owner-Manager, Vol. 9, No. 4, October, 2009, p. 4.
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|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 229 | 0 |
Subsection 152(1.6)
Cases
Menzies v. The Queen, 2016 TCC 73 (Informal Procedure)
After finding that the presumption in s. 244(20), that notice to the general partner of an LP is notice to all the partners, is conclusive rather...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(20) | notice provided to a GP is irrebuttably notice to all the limited partners | 160 |
Subsection 152(1.7) - Binding effect of determination
See Also
Cummings v. The Queen, 2009 DTC 953, 2009 TCC 310
The taxpayer was a member of a partnership which, through its counsel, entered into a settlement agreement with the Minister on March 31, 2004...
Subsection 152(1.12) - When determination not to be made
See Also
Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251
The Minister made an assessment under s. 152(1.11) on the basis that the GAAR applied to reduce the paid-up capital of shares of a Canadian...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | payment by direction | 142 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | limited scope of PUC provisions reflected a policy choice | 289 |
| Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity | 72 |
Subsection 152(2) - Notice of assessment
Cases
Flanagan v. The Queen, 87 DTC 5390 (FCA)
A reassessment notice was not 'sent' within the meaning of this provision when (during a postal strike) a Revenue Canada employee attended at the...
Stephens v. The Queen, 87 DTC 5024, [1987] 1 CTC 88, 87 DTC 5024 (FCA)
The requirements of s. 152(2) were satisfied when a reassessment bore the words "Revenue Canada Taxation" (rather than the Department of National...
Re Charron, 84 DTC 6241, [1984] CTC 237 (FCTD)
"All that Section 152(2) of the Income Tax Act requires is that the Minister 'shall send a Notice of Assessment' ... . It was quite properly sent...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation - Constitution Act, 1982 - Paragraph 11(d) | 45 | |
| Tax Topics - Other Legislation - Constitution Act, 1982 - Section 8 | 25 | |
| Tax Topics - Income Tax Act - Section 158 - Subsection 158(2) | 153 |
Burroughs v. The Queen, 82 DTC 6340, [1982] CTC 414 (FCTD)
A reassessment notice was sent when, during a Canadian postal strike, it was mailed to the taxpayer from a United States Post Office.
Jobin v. The Queen, 78 DTC 6538, [1978] CTC 493 (FCTD)
The Minister is not limited to pleading sections of the Act to which he referred in his Notice of Assessment.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(2) | 75 |
See Also
McIntyre v. MNR, 93 DTC 999 (TCC)
Notices of reassessment that were sent by registered mail by the Minister were returned by the post office, with the envelopes marked "unclaimed"....
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|---|---|---|
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(14) | 114 |
Subsection 152(3) - Liability not dependent on assessment
Cases
The Queen v. Leung, 93 DTC 5467 (FCTD)
A reassessment of a director in respect of the aggregate amount of source deductions which the corporation had failed to make under the Act and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | 82 | |
| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) | 82 |
Subsection 152(3.1)
Administrative Policy
10 March 2016 Internal T.I. 2015-0614161I7 - Extended reassessment period 152(4)(b)
Where Canadian-controlled private corporation was issued an original notice of assessment for a particular taxation year on December 31, 2013, the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 27 - Subsection 27(3) | normal or extended reassessment period ends on the anniversary date | 200 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) | extended reassessment period ends on the assessment anniversary date | 44 |
29 April 2014 Internal T.I. 2013-0481581I7 - Under Remittance of Part XIII Tax
The normal reassessment period for failure to withhold at the proper rate will commence to run once an amount has been assessed under s....
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| Tax Topics - Income Tax Act - Section 227 - Subsection 227(10) - Paragraph 227(10)(d) | acceptance by CRA of remittance and resulting notification is not an assessment | 164 |
31 October 1994 Memorandum 941233
Where an original notice of "nil" assessment is statute-barred, the Department nonetheless is entitled to revise the loss as long as it does not...
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | 76 |