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Canada (Attorney General), 2025 FC 926-- summary under Subsection 207.06(1) Summary Under Tax Topics- Income Tax Act- Section 207.06- Subsection 207.06(1) CRA required to reconsider cancelling tax under s. 207.06(1) given inconsistencies in the record as to when CRA notified of the TFSA over-contribution The taxpayer sought cancellation pursuant to s. 207.06(1) of the taxes for which she had been assessed in respect of her excess contributions to her TFSA for her 2021 and 2022 taxation years. ...

Minister of National Revenue, 2025 FC 814-- summary under Subsection 220(3.2) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.2) application of principle that the CRA “obligation of fairness in reaching a decision under the VDP program is minimal” In June 2019, the applicant filed an application under the voluntary disclosure program (VDP) for its 2008 to 2017 taxation years, which related to income generated from the investment of the proceeds of the sale of cumulative eligible capital (know-how) to clients in Europe in 2007. ...