Ford Motor Co. – Tax Court of Canada finds that it is sufficient for only CRA to be able to understand the issues raised in a Notice of Objection

The ITA large corporation and ETA specified person rules deny the right to appeal an issue that was not identified (and quantified) in the notice of objection. Boyle J has found that all that is required here is that the Minister (as opposed to a third party such as a Justice lawyer or a Tax Court Justice) "be able to understand the scope and quantum of the issue from its description in the notice of objection" – so that it was sufficient for the notice to say not much more than "I hereby object that you did not allow the unclaimed ITCs and FX adjustments that I previously brought to your attention" (before quantifying the requested adjustments).

Neal Armstrong. Summary of Ford Motor Company of Canada, Ltd. v. The Queen, 2015 TCC 39, under ETA s. 306.1(1).