CRA indicates it will assign a second appraiser on an appraisal appeal, who generally reviews the original appraisal rather than preparing a 2nd

CRA seemed to confirm that where a builder appeals a CRA assessment made under ETA s. 191(3) that challenged the FMV used by the builder at the time of first occupancy:

  • CRA Appeals will refer the valuation issue to a second CRA appraiser, rather than the original appraiser;
  • it will not generally ask the second appraiser to prepare a second appraisal (so that, by implication, the second appraiser generally will only review the first appraisal and, perhaps, supplement it); and
  • there is no policy that the original appraiser cannot have contact with Appeals.

Neal Armstrong. Summary of 25 March 2021 CBA Commodity Taxes Roundtable, Q.2 under ETA s. 191(3).