684761 B.C. Ltd. – Tax Court of Canada confirms CRA’s ability to issue additional assessments without voiding previous reassessments

CRA reassessed the taxpayer within the normal reassessment period, and then issued a “Notice of Additional Assessment” assessing penalties under ss. 163(1) and (2) beyond the normal reassessment period. The taxpayer argued that CRA had inappropriately “bifurcated one assessment process into two distinct products” - and the additional assessment was in substance a reassessment so that it displaced the previous reassessment. In rejecting this submission, Rip J noted that the subsequent assessment was indeed an additional assessment, and rather than being esoteric, it was one of the tools available to CRA.

Neal Armstrong. Summary of 684761 B.C. Ltd. v. The Queen, 2015 TCC 288, under s. 152(4).