CRA assessments under a GST/HST voluntary disclosure by a supplier permit a s. 225(4)(c) extension of the period for its customer to claim an ITC

A Notice of Assessment is issued by CRA once a GST/HST voluntary disclosure is finalized. This permits a supplier who has disclosed a failure to charge GST/HST on a taxable supply made more than four years prior to such assessment to disclose such assessment to its customer, so that s. 225(4)(c) can operate to extend the normal four-year period for the customer to claim an input tax credit for GST/HST that is now charged to it and paid by it on the supply from the assessed supplier.

Neal Armstrong. Summary of 28 February 2019 CBA Roundtable, Q.21 under s. 225(4)(c).