Robert Kopstein, Rebecca Levi, "When Should the Courts Allow Reassessments Beyond the Limitation Period", Canadian Tax Journal, (2010) Vol. 58, No. 3, 475-527

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i)

After a lengthy review of the jurisprudence on late assessments, the authors stated (at pp. 509-11):

The following circumstances were found by the...

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Summary Under
Tax Topics - General Concepts - Solicitor-Client Privilege

In the course of an extensive criticism and review of s. 152(4)(a)(i), the authors stated (at pp. 521-22):

A related issue arises where the CRA...

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