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This registration-date issue was not resolved until over three months later, when CRA changed the effective date of the registration to August 1, 2012. 353 then refiled the returns for those earlier reporting periods during which it previously had not been registered, and on November 7, 2017, CRA assessed 353’s returns – but apparently not the initial three quarters. ...

Regarding the CRA position that, even if it had the discretion under s. 220(3) to accept the filing of a new T5013 return, no extension was appropriate, Régimbald J found (at para. 134) that CRA had failed to consider inter alia that its reassessment “would create injustices” given Onex’s representations that “they always intended to benefit from the ultimate tax result now provided by Bill C-43, and that their request was not an attempt at retroactive tax planning” – and that CRA had “failed to explain why, in its view, the ‘harsh consequences’ in this case better reflected Parliament’s intention” (para. 141). ...

. … [The 2021] notices of objection have not been adjudicated. In light of these circumstances, quashing the Minister’s decision to reassess may therefore have the practical effect of ordering the Minister to reconsider her decision. ...