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Canada (Attorney General), 2018 FC 53-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) CRA failed to consider whether late T1135s were filed “voluntarily” for earlier years notwithstanding subsequent years being under review On March 17, 2015, the taxpayer, which was a Canadian corporation that had held land in Ghana at all relevant times, submitted T1135 returns for its 2005 to 2013 years under the voluntary disclosure program (VDP). ... However, the taxpayer’s 2005 to 2010 T2 returns had been filed and assessed. ... Ahmed J found (at para 26) that, respecting the 2011-2013 T2 returns, “the enforcement action taken by the CRA would likely have uncovered its obligation to file T1135 returns. … I believe it was reasonable for the Minister’s Delegate to conclude that a CRA agent would seek to follow up with the Applicant regarding its obviously missing T1135 return.” ...

Canada (National Revenue), 2019 FC 1599-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) CRA required to consider waiver of interest that accrued during a three-year delay in dealing with a late-filed Objection In 2008 the CRA contacted the taxpayer to ask him to provide supporting documents to prove commission expenses for the 2005 to 2006 taxation years, which he was unable to do as his former partner, who had also been his landlord, had destroyed the partnership documents, and his former spouse had also withheld correspondence and destroyed documents relevant to those taxation years. ... Favel J found that the taxpayer had implicitly requested the Minister for an extension pursuant to s. 166.1 of the time for objecting, stating (at para. 50): Notices of Objection filed after the 90 day delay for objecting, but within the extension of time delay, have been interpreted as implicit applications to extend time …. ... Rather, the Minister remained passive for two years …. The Minister’s analysis of delays imputable to the CRA is limited to those incurred between the TCC order of February 26, 2013 and the assignment of the Applicant’s file to an appeal officer in November 2013, and consequently, at the initial level, cancelled interest for one month during that period (October 2013) to account for the delay. ...

He also stated (at paras. 13-14): Toronto Star Newspaper Ltd v Ontario, 2005 SCC 41 [stated]: 1. In any constitutional climate, the administration of justice thrives on exposure to light — and withers under a cloud of secrecy. 2. ...

Following a 2005 audit, CRA offered to settle the issues arising from the 2001 and 2002 taxation years if the taxpayer signed a waiver of his appeal rights for both years respecting his business income and expenses. ... In finding that CRA’s decision should stand, and in rejecting a submission (at para. 23) that “it was unfair for the Minister’s delegate not to ‘match’ the expenses he incurred in paying the rental payments for the two machines against the income he earned by using the machines, and…although his corporation’s name was on the lease with CIT, the corporation was in fact inactive,” Bowell J stated (at paras. 24 to 26): [T]he matching principle is not a rule of law which dictates or requires that expenses must always be matched with profits; it is simply an accounting principle that a court may or may not consider depending upon the particular facts and circumstances of a case. … …The Applicant chose to collect revenue generated by the machines personally, rather than through his corporation, and he cannot rely upon an accounting principle to ignore the legal reality of the lease and argue that the cost of the lease payments should be attributed to him personally and deductible from his personal income for the 2001 taxation year. …... ...