Granofsky – Tax Court of Canada finds that a taxpayer’s counsel can consent in writing to reassessment of the taxpayer

S. 169(3) provides that Minister may at any time reassess, with the consent in writing of “the taxpayer.” D’Auray J found that this requirement can be satisfied through a signature of the taxpayer’s counsel acting within the scope of her mandate (and went on to find that, in the case before her, counsel had the mandate).

Neal Armstrong. Summary of Granofsky v. The Queen, 2016 TCC 181 under s. 169(3).