CRA indicates that a federal assessment of a return with no mention of an agreeing province starts the normal reassessment period running for that province

CRA indicated that the normal reassessment period for taxes payable in an agreeing province begins with the sending of the federal assessment, even if there was no reporting in the assessed return regarding that agreeing province (e.g., by not including the form for that province with the return). Thus, where a trust that CRA considered to have been resident in Ontario had reported all along on the basis that it was resident in Alberta, CRA’s initial assessment of the trust federally and in Alberta for a particular year would start the normal reassessment period running for that year regarding any subsequent reassessment of Ontario tax. CRA noted that this view was consistent with Aubrey Dan.

Neal Armstrong. Summary of 24 September 2020 Internal T.I. 2020-0841041I7 under s. 152(4).