Subsection 301(1)
Administrative Policy
25 March 2021 CBA Commodity Taxes Roundtable, Q.1
CRA confirmed that where an appeal of the builder against a CRA assessment under s. 191(3) (showing an increased FMV of a new multiple unit...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 298 - Subsection 298(6) | CRA can consequentially assess to reduce rebates if, following an objection or appeal, it reduces a s. 191(3) assessment | 148 |
Subsection 301(1.1)
Cases
Canada v. Schafer, 2000 DTC 6542 (FCA)
The appellant had been found by the trial judge not to have received a notice of assessment. The Court found that the "sent" wording of s....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 334 - Subsection 334(1) | 95 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(7) | 34 | |
| Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | "deems" is irrebuttable | 68 |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 57 |
See Also
Xu v. The King, 2022 TCC 108 (Informal Procedure)
On August 26, 2019, the Minister reassessed the taxpayers for the full amount of a new residential rental unit rebate (“rebate”), previously...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) | an informal letter qualified as a notice of objection | 120 |
International Hi-Tech Industries Inc. v. The Queen, 2014 TCC 198
Prior to its bankruptcy, the appellant granted a general security agreement ("GSA") to its parent and related companies as security for a $6...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 266 - Subsection 266(2) | secured creditors able to bring claim for ITCs of bankrupt | 277 |
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 29 | secured creditors able to bring claim for ITCs of bankrupt | 324 |
Administrative Policy
8 March 2018 CBA Commodity Tax Roundtable, Q.6
- If a taxpayer is objecting to multiple Notices of Assessment, where the same issues are raised, will CRA accept a single Form GST159 with the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) | single objection form can cover multiple GST assessments | 27 |
Forms
GST159 Notice of Objection (GST/HST)
File separate notice for each reassessment and comply with specified person particulars
File a separate form for each notice in dispute.
Specified...
Subsection 301(3)
Administrative Policy
7 April 2022 CBA Roundtable, Q.1
Where a builder objects to a reassessment that is based on the determination of a higher FMV of the property, in what situations, if any, would...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | an Appeals Officer can (and may) increase the reassessment under appeal | 66 |
25 March 2021 CBA Commodity Taxes Roundtable, Q.13
(a) Where additional documentation becomes available after an objection is with the appeals officer, must that officer review and analyze the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | protocol for referrals by Appeals back to Audit | 174 |
Subsection 301(4)
Administrative Policy
27 February 2020 CBA Roundtable, Q.2
Regarding its policy regarding requests under s. 301(4) for the Minister to waive reconsideration of an objection, CRA stated:
On receipt of...