Subsection 334(1) - Sending by Mail
Cases
Canada v. Schafer, 2000 DTC 6542 (FCA)
The appellant had been found by the trial judge not to have received a notice of assessment. The Court found that the "sent" wording of s. 301(1.1) was clear and unambiguous, and that therefore there is not requirement that the notice be received in order to start the limitation running. The Court found that even if s. 301(1.1) had not applied to start the limitation period running from the date of mailing of the notice of assessment, s. 334(1) applied to deem the respondent to have received the notice of assessment on the date of mailing.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 301 - Subsection 301(1.1) | 52 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(7) | 34 | |
| Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | "deems" is irrebuttable | 68 |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 57 |