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19 March 2025- 11:20pm Csak – FCA confirms a s. 160 challenge on the basis that a TCC judgment of the transferor was incorrect, and confirms that a waiver time limit falling on a Sunday was extended Email this Content The taxpayer challenged assessments of her under s. 160(2) respecting unpaid tax of her late husband for his 1988 and 1989 taxation year by arguing that the CRA assessments of him for those years were statute-barred given that CRA had not received a waiver on a timely basis (which had been found by Owen J to be the case for his 1988 taxation year and, in the case of his 1989 taxation year, turned on the proposition that the receipt by CRA of a waiver on a Monday was one day following the expiry of the normal reassessment period on the Sunday). ... It provides relief when the time limit for doing a thing expires on a holiday, allowing the thing to be done on the next day that is not a holiday. … I am satisfied that the filing of a waiver is the “doing of a thing” for the purposes of section 26 …. … I do not view the time limited for filing a waiver as conceptually different for this purpose from the deadlines for filing a notice of objection or notice of appeal …. ... Csak, 2025 FCA 60 under s. 160(2), s. 152(4)(a)(ii) and General Concepts – Abuse of Process. ...