Cases
Canada v. Gray, 2008 DTC 6641, 2008 FCA 284
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Ludmer v. The Queen, 95 DTC 5311 (FCA)
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|---|---|---|
| Tax Topics - General Concepts - Estoppel | 132 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 43 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 61 |
The Queen v. Regina Shoppers Mall Ltd., 91 DTC 5101 (FCA)
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | 122 |
Optical Recording Corp. v. The Queen, 86 DTC 6465, [1986] 2 CTC 454 (FCTD), aff'd 87 DTC 5248, [1987] 1 CTC 417
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| Tax Topics - General Concepts - Estoppel | 101 | |
| Tax Topics - Income Tax Act - Section 195 - Subsection 195(2) | 29 |
Hadler Turkey Farms Inc. v. The Queen, 86 DTC 6013, [1986] 1 CTC 81 (FCTD)
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| Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) | 49 |
See Also
Aubrey Dan Family Trust v. Minister of Finance, 2016 ONSC 3801
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| Tax Topics - Other Legislation/Constitution - Ontario - Taxation Act 2007 - Section 158 | federal form with CRA insignia purported to be a prescribed form | 328 |
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(16) | form bearing CRA insignia purported to be prescribed form | 76 |
Hall v. The Queen, 2016 TCC 221 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 204.1 - Subsection 204.1(4) | waiver of tax of mentally ill taxyaer recommended | 120 |
| Tax Topics - Income Tax Act - Section 204.3 - Subsection 204.3(2) | assessment of Pt I returns did not start Pt X.1 statute-barring period running | 69 |
684761 B.C. Ltd. v. The Queen, 2015 DTC 1228 [at 1507], 2015 TCC 288
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Klemen v. The Queen, 2014 DTC 1170 [at 3613], 2014 TCC 244
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Commercial Activity | equipment licensed at no charge was held in commercial activity | 84 |
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(5) | s. 165(5) cannot be used to increase an assessment | 151 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment | licensed equipment internally transferred in one-off transaction | 176 |
Fio Corporation v. The Queen, 2014 TCC 58
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| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | inherent jurisdiction to void reassessments which breach undertaking | 139 |
| Tax Topics - Income Tax Act - Section 241 | s. 241 does not override implied undertaking rule | 143 |
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Act - Section 17.2 | time of commencement of appeal | 138 |
Nottawasaga Inn Ltd. v. The Queen, 2014 DTC 1021 [at 2628], 2013 TCC 377 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 169 | 285 |
Yazdani v. The Queen, 2012 DTC 1303 [at 3983], 2012 TCC 371 (Informal Procedure)
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Blackburn Radio Inc. v. The Queen, 2012 DTC 1213 [at 3580], 2012 TCC 255
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.3) | no further reassessment permitted if order to vacate or vary | 286 |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | no further reassessment permitted if order to vacate or vary | 173 |
Administrative Policy
S3-F4-C1 - General Discussion of Capital Cost Allowance
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29 July 2015 Internal T.I. 2015-0575921I7 - Recapture arising in statute-barred years
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) | negative UCC balance arising in statute-barred year becomes recapture in 1st open year | 438 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - E | negative UCC balance arising in statute-barred year becomes recapture in 1st open year | 227 |
15 September 2015 Internal T.I. 2015-0572771I7 - T1135 - Normal Reassessment Period
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| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | unlike s. 216 returns, the assessment of s. 162(7) penalties is subject to the same normal reassessment period as for the Part I return | 89 |
18 November 2014 TEI Roundtable, 2014-0550381C6 - 2014 TEI Liaison Meeting, Q.E2 - Capital Cost Allowance (CCA) Claimed under Paragraph 20(1)(a)
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14 April 2014 External T.I. 2014-0521341E5 - Unclaimed interest expense
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7 February 2014 Internal T.I. 2013-0512601I7 - Clarification of 2013-0481151I7
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| Tax Topics - Income Tax Act - 101-110 - Section 110.5 | 110.5 addition not a permissible 84-1 adjustment | 117 |
11 October 2013 Internal T.I. 2013-0475761I7 - Deadline for filing a waiver of tax credit – ORDTC
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12 December 2013 Internal T.I. 2013-0497231I7 - Penalties on Foreign Asset Reporting
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| Tax Topics - Income Tax Act - Section 162 - Subsection 162(10.1) | normal reassessment period does not apply | 52 |
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(10) | normal reassessment period does not apply | 132 |
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | s. 152(4)(a) applies to Part XV returns | 81 |
16 July 2013 Internal T.I. 2013-0481151I7 - Application of 152(4)(b)(iv) and 110.5
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| Tax Topics - Income Tax Act - 101-110 - Section 110.5 | extended s. 152(4)(b)(iv) period/IC 84-1 | 207 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iv) | 207 |
25 March 2013 Internal T.I. 2013-0474111I7 - Amendment to Prior Years' CCA
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11 December 2012 Internal T.I. 2012-0459341I7 - Adjustments Beyond Normal Reassessment Period
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31 October 1994 Memorandum 941233
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(3.1) | 35 |
28 February 1991 T.I. 8621-4
88 C.R. - Q.77
84 C.R. - Q.88
IC 84-1 "Revision of Capital Cost Allowance Claims and Other Permissive Deductions"
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(a) - Revising Claims | 156 |
79 C.R. - Q.14
Articles
Beith, "Fairness Package", 1992 Conference Report, c.7.
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| Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) | 0 |
Paragraph 152(4)(a)
Subparagraph 152(4)(a)(i)
Cases
Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375
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| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | not necessary to provide legal opinion to rely on having consulted legal counsel | 215 |
| Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) | no fixed place of “business” if no source of business income | 165 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | Marconi test of "business" applied outside source-of-income context | 136 |
| Tax Topics - Statutory Interpretation - French and English Version | "misrepresentation" informed by narrower French version | 103 |
Vine Estate v. Canada, 2015 DTC 5063 [at 5880], 2015 FCA 125
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| Tax Topics - General Concepts - Onus | onus does not shift to taxpayer to disprove neglect, carelessness, or wilful default | 160 |
Vachon v. Canada, 2014 FCA 224
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Middlebrook v. Canada, 2013 DTC 5001 [at 5501], 2012 FCA 264
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Canada v. Johnson, 2013 DTC 5004 [at 5515], 2012 FCA 253
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| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | contractual payments derived from Ponzi scheme were income | 249 |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | taxable gains from contract with Ponzi operator | 249 |
Lacroix v. Canada, 2008 FCA 241
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | net worth assessment | 352 |
Gebhart v. Canada, 2008 DTC 6581, 2008 FCA 206
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Ridge Run Developments Inc. v. The Queen, 2007 DTC 734, 2007 TCC 68
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Naguib v. Canada, 2004 DTC 6082, 2004 FCA 40
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Can-Am Realty Ltd. v. The Queen, 97 DTC 5070 (FCTD)
Nesbitt v. The Queen, 96 DTC 6045 (FCTD)
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Can-Am Realty Ltd. v. The Queen, 94 DTC 6293 (FCTD)
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 95 |
1056 Enterprises Ltd. v. The Queen, 89 DTC 5287 (FCTD)
Davis v. The Queen, 84 DTC 6518, [1984] CTC 564 (FCTD)
Patricio v. The Queen, 84 DTC 6413 (FCTD)
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 99 |
Venne v. The Queen, 84 DTC 6247, [1984] CTC 223 (FCTD)
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 67 |
Reilly Estate v. The Queen, 84 DTC 6001, [1984] CTC 21 (FCTD)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 92 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 30 |
MNR v. Bisson, 72 DTC 6374 (FCTD)
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 220 |
MNR v. Foot, 64 DTC 5196 (Ex Ct), briefly aff'd 66 DTC 5072 (SCC)
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See Also
Thompson v. The Queen, 2017 TCC 115
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Mont-Bruno C.C. Inc. v. The Queen, 2016-1152(IT)G, 21 March 2017
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| Tax Topics - Income Tax Act - Section 149 - Subsection 149(5) - Paragraph 149(5)(e) - Subparagraph 149(5)(e)(ii) | not clear negligence to not report sale of adjoining wooded lands | 171 |
Krenbrink Estate v. The Queen, 2014 DTC 1065 [at 2996], 2014 TCC 22
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Francis & Associates v. The Queen, 2014 DTC 1146 [at 3468], 2014 TCC 137 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | subsequently discovered bad debts not claimable; unbilled disbursements deductible under s. 9 | 235 |
Desmarais v. The Queen, 2013 DTC 1044 [at 2804], 2013 TCC 356 (Informal Procedure)
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832866 Ontario Inc. v. The Queen, 2014 TCC 93 (Informal Procedure)
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| Tax Topics - Excise Tax Act - Section 298 - Subsection 298(4) - Paragraph 298(4)(a) | failure to query GST treatment of self-supply | 174 |
Ross v. The Queen, 2013 DTC 1250 [at 1400], 2013 TCC 333
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) | 353 | |
| Tax Topics - Income Tax Regulations - Regulation 8502 - Paragraph 8502(a) | 312 |
Bandula v. The Queen, 2013 DTC 1225 [at 1238], 2013 TCC 282
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | new immigrant | 67 |
De Couto (Alco Windows Inc.) v. The Queen, 2013 DTC 1161 [at 880], 2013 TCC 198 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | dismal records but no deceit | 104 |
Aridi v. The Queen, 2013 DTC 1189 [at 1015], 2013 TCC 74
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Lenneville v. The Queen, 2013 DTC 1196 [at 1045], 2013 TCC 56
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | net worth assessment did not prove misrepresentation | 122 |
Roud Estate v. The Queen, 2013 DTC 1057 [at 309], 2013 TCC 36 (Informal Procedure)
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Schmidt v. The Queen, 2013 DTC 1063 [at 337], 2013 TCC 11
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | alleged family loan was credible | 103 |
Grossett v. The Queen, 2012 DTC 1185 [at 3465], 2012 TCC 179 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | 51 |
Mullen v. The Queen, 2012 DTC 1154 [at 3358], 2012 TCC 139 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) | 39 | |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | superficial attempt to change residence | 195 |
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | 223 |
9067-9051 Québec Inc., Vincent v. The Queen, 2012 DTC 1073 [at 2842], 2011 TCC 456
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 152(4)(a)(i) is lesser threshold | 71 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 190 |
D'Andrea v. The Queen, 2011 DTC 1234 [at 1356], 2011 TCC 298
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 146 |
Ha v. The Queen, 2011 TCC 271
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| Tax Topics - Excise Tax Act - Section 298 - Subsection 298(4) - Paragraph 298(4)(a) | 88 |
Palardy v. The Queen, 2011 DTC 1188 [at 1050], 2011 TCC 108
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| Tax Topics - Income Tax Act - Section 54 - Principal Residence | 143 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 118 |
Cameron v. Queen, 2011 DTC 1166 [at 914], 2011 TCC 107
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Stanislao Calandra o/a Calandra Hair Studio v. The Queen, 2011 DTC 1049 [at 142], 2011 TCC 7 (Informal Procedure)
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Misiak v. The Queen, 2011 DTC 1048 [at 237], 2011 TCC 1 (Informal Procedure)
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Envision Credit Union v. The Queen, 2010 DTC 1399 [at 4585], 2010 TCC 576, aff'd 2012 DTC 5055 [at 6842], 2011 FCA 321, aff'd 2013 DTC 5144 [at 6275], 2013 SCC 48
Labow v. The Queen, 2010 TCC 408, 2010 DTC 1282 [at 3956], aff'd 2012 DTC 5001 [at 6501], 2011 FCA 305
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | health plan was disguised deferral scheme | 54 |
Létourneau v. The Queen, 2010 DTC 1232 [at 3656], 2010 TCC 203
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Chaumont v. The Queen, 2010 DTC 1014 [at 2599], 2009 TCC 493 (Informal Procedure)
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Donato v. The Queen, 2009 DTC 1384 [at 2111], 2009 TCC 590
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| Tax Topics - Income Tax Act - Section 54 - Personal-Use Property | 50 |
Sljivar v. The Queen, 2009 DTC 1381 [at 2103], 2009 TCC 581
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(ii) | 56 |
Wachsmann v. The Queen, 2009 TCC 420
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College Park Motor Products Ltd. v. The Queen, 2009 DTC 1469, 2009 TCC 409
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Dalphond v. The Queen, 2009 DTC 1395, 2008 TCC 427, aff'd 2010 DTC 5016 [at 6589], 2009 FCA 121
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O'Dea v. The Queen, 2009 DTC 912, 2009 TCC 295
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|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | no evidence of payment through off-settable cash | 85 |
| Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) | 134 | |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 47 | |
| Tax Topics - Income Tax Act - Section 96 | 54 |
Séguin Boyer v. The Queen, 2008 DTC 4891, 2008 TCC 88
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 38 |
Savard v. The Queen, 2008 TCC 62
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 75 |
Abakhan & Associates Inc. v. Canada (Attorney General), 2008 DTC 6028, 2007 FC 1327
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Mensah v. The Queen, 2008 DTC 4358, 2008 TCC 378
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 28 |
McKellar v. The Queen, 2007 DTC 1007, 2007 TCC 266
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Peek v. The Queen, 2007 DTC 602, 2007 TCC 152
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| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | cheque kiting operation | 27 |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 27 |
Petric v. The Queen, 2006 DTC 3082, 2006 TCC 306
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S.E.R. Contracting Ltd. v. The Queen, 2006 DTC 2212, 2006 TCC 6 (Informal Procedure)
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Succession de Feu Cléophas Saint-Aubin c. La Reine, 2005 DTC 912, 2003 TCC 608
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Riordan v. The Queen, 2005 DTC 397, 2005 TCC 150
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 112 |
Central Interior Incorporated v. The Queen, 2005 DTC 144, 2004 TCC 725
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Jencik v. The Queen, 2004 TCC 295 (Informal Procedure)
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Sidhu v. The Queen, 2004 DTC 2540, 2004 TCC 174
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| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) | must be unequivocal inconsistent use | 118 |
| Tax Topics - Income Tax Act - Section 54 - Principal Residence | 98 |
Produits Forestiers St-Armand Inc. c. La Reine, 2004 DTC 2494, 2003 TCC 696
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Snowball v. The Queen, 97 DTC 512 (TCC)
Farina v. The Queen, 97 DTC 487 (TCC)
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 47 |
Prévost v. MNR, [1996] 1 CTC 2701 (TCC)
Ver v. Canada, [1995] TCJ No. 593
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Farm Business Consultants Inc. v. The Queen, 95 DTC 200 (TCC), briefly aff'd 96 DTC 6085 (FCA)
Abogado v. The Queen, 96 DTC 3254 (TCC)
Gauthier v. MNR, 93 DTC 758 (TCC)
Poulin v. MNR, 87 DTC 113 (TCC)
Markakis v. MNR, 86 DTC 1237 (TCC)
Administrative Policy
May 2016 Alberta CPA Roundtable, Q.17
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| Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) | T1135 filings for all years required | 33 |
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | penalty not an absolute liability penalty | 87 |
26 May 2016 Alberta CPA Roundtable, 2016-0645001C6 - Failure to file Form T1135
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| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | failure to file a T1135 may not indicate carelessness or neglect | 83 |
4 December 2014 Internal T.I. 2014-0526451I7 F - Assessment beyond the normal reassessment period
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30 June 2014 Internal T.I. 2013-0508411I7 F - Part IV Tax and the Dividend Refund
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| Tax Topics - Income Tax Act - Section 186 - Subsection 186(1) | when to stop circular calculation for cross dividends | 238 |
14 July 2014 Internal T.I. 2014-0537701I7 F - Voluntary disclosure - T1134 and FAPI
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| Tax Topics - Income Tax Act - Section 162 - Subsection 162(10) | penalties for failure to file T1134s | 132 |
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | penalties for failure to file T1134s | 132 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2.4) | penalties for failure to file T1134s | 132 |
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) | requirements where undisclosed FAPI | 197 |
5 June 2014 Internal T.I. 2013-0509051I7 - Penalties beyond the Normal Reassessment Period
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| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | carelessness sufficient to assess beyond normal reassessment period | 58 |
11 June 2014 Internal T.I. 2014-0519701I7 - Filing a NIL return to avoid late-filing penalties
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| Tax Topics - Income Tax Act - Section 162 - Subsection 162(1) | return with substantive missing elements | 119 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | return with substantive missing elements | 55 |
9 November 2012 CTF Atlantic Roundtable, 2012-0465921C6 - CTF Atlantic - Statute Barred Years
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21 September 2012 Internal T.I. 2012-0447401I7 - Minister's ability to reassess under 152(4)
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2 February 2005 Internal T.I. 2005-011324 -
October 1992 Central Region Rulings Directorate Tax Seminar, Q. I (May 1993 Access Letter, p. 230) Discussion comparing the conduct described in s. 163(2) and s. 152(4)(a)(i).
Articles
Robert Kopstein, Rebecca Levi, "When Should the Courts Allow Reassessments Beyond the Limitation Period", Canadian Tax Journal, (2010) Vol. 58, No. 3, 475-527
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| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 125 |
Brent F. Murray, "Extending the Assessment Limitation Period", Canadian GST Monitor, No. 275, August 2011, p. 1.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 298 - Subsection 298(4) - Paragraph 298(4)(a) | 0 |
Krishna, "Reassessments Based on Fraud or Misrepresentation", Canadian Current Tax, October 1992, p. A25.
Subparagraph 152(4)(a)(ii)
Cases
Arpeg Holdings Ltd v. The Queen, 2007 DTC 131, 2006 TCC 593
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| Tax Topics - General Concepts - Agency | 83 | |
| Tax Topics - General Concepts - Non Est Factum | 78 |
Mitchell v. Canada, 2002 DTC 7502, 2002 FCA 407
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| Tax Topics - Statutory Interpretation - Interpretation Act - Section 32 | 24 |
Mitchell v. Attorney General of Canada, 2001 DTC 5290 (FCTD)
Solberg v. The Queen, 92 DTC 6448 (FCTD)
See Also
Remtilla v. The Queen, 2015 TCC 200
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Rémillard v. The Queen, 2011 DTC 1286 [at 1617], 2011 TCC 327
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(15.1) | 114 |
Sljivar v. The Queen, 2009 DTC 1381 [at 2103], 2009 TCC 581
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | didn't review return | 39 |
Brown v. The Queen, 2006 DTC 3274, 2006 TCC 381
Chafetz v. The Queen, 2006 DTC 2119, 2005 TCC 803
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) | 143 |
Villeneuve v. The Queen, 2004 DTC 2258 (TCC), rev'd 2004 DTC 6077 (FCA)
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 75 |
Mierins v. The Queen, 96 DTC 1140 (TCC)
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | 84 |
Loukras v. MNR, 90 DTC 1557 (TCC)
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| Tax Topics - Income Tax Act - Section 44 - Subsection 44(2) - Paragraph 44(2)(b) | 36 |
Administrative Policy
15 June 2015 Internal T.I. 2015-0583081I7 - Refund Request - Normal Reassessment Period
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| Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) | inferring refund request from waiver | 137 |
15 March 2013 Internal T.I. 2012-0468081I7 - Paragraph 164(1)(b)
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| Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) | refund request not related to issues in waiver issues | 113 |
14 May 1991 T.I. (Tax Window, No. 3, p. 26, ¶1232)
87 C.R. - Q.44
87 C.R. - Q.45
85 C.R. - Q.2
IT-270R2 "Foreign Tax Credit", para. 14
IC 75-7R3 "Reassessment of a Return of Income"
Articles
Paragraph 152(4)(b)
Cases
Canada v. Agazarian, 2004 DTC 6366, 2004 FCA 32
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) | 52 | |
| Tax Topics - Statutory Interpretation - French and English Version | 113 | |
| Tax Topics - Statutory Interpretation - Legislative History | 72 |
Clibetre Exploration Ltd. v. Canada (Minister of National Revenue), 2003 DTC 5073, 2003 FCA 16
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Agazarian v. The Queen, 2003 DTC 435 (TCC)
Paramount Productions Inc. v. The Queen, 93 DTC 5285 (FCTD)
Placer Dome Inc. v. The Queen, 91 DTC 5115 (FCTD)
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| Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity | change prejudicial so that presumption applied | 123 |
See Also
Leola Purdy Sons Ltd. v. The Queen, 2009 DTC 220, 2009 TCC 21
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Papiers Cascades Cabano Inc. c. La Reine, 2006 DTC 2305, 2005 TCC 396
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| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Investment Tax Credit | 138 |
VIH Logging Ltd v. The Queen, 2004 DTC 2090, 2003 TCC 732
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| Tax Topics - General Concepts - Evidence | 62 | |
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(14) | 79 |
Administrative Policy
10 March 2016 Internal T.I. 2015-0614161I7 - Extended reassessment period 152(4)(b)
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| Tax Topics - Statutory Interpretation - Interpretation Act - Section 27 - Subsection 27(3) | normal or extended reassessment period ends on the anniversary date | 190 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(3.1) | normal reassessment period ends on the assessment anniversary date | 35 |
1993 A.P.F.F. Round Table, Q.9
Subparagraph 152(4)(b)(iii)
See Also
Ho v. The Queen, 2010 DTC 1214, 2010 TCC 325
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Shaw-Almex Industries Limited v. The Queen, 2009 DTC 1377 [at 2080], 2009 TCC 538
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 116 |
Administrative Policy
16 January 2017 Internal T.I. 2016-0651411I7 - Reassessment period – transfer pricing
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| Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(3) - Paragraph 402(3)(a) - Subparagraph 402(3)(a)(i) | reallocation of gross revenue consequential on s. 247(2) assessment | 94 |
22 April 2013 Internal T.I. 2013-0478121I7 - Application of 152(4)(b)(iii)
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5 December 2012 Internal T.I. 2012-0439301I7 F - Reassessment beyond the normal reassessment period
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| Tax Topics - Income Tax Act - Section 96 | partnership lacks power to contract debts | 141 |
22 March 2012 External T.I. 2011-0407731E5 - Application of Subparagraph 152(4)(b)(iii)
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(c) | 165 |
Subparagraph 152(4)(b)(iv)
Administrative Policy
16 July 2013 Internal T.I. 2013-0481151I7 - Application of 152(4)(b)(iv) and 110.5
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| Tax Topics - Income Tax Act - 101-110 - Section 110.5 | extended s. 152(4)(b)(iv) period/IC 84-1 | 207 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | s. 110.5 addition | 77 |
9 December 2010 Internal T.I. 2010-0379801I7 - Additions to taxable income to utilize FTCs
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| Tax Topics - Income Tax Act - 101-110 - Section 110.5 | non-extended adjustment period/84-1 not available | 270 |
Paragraph 152(4)(b.2)
Administrative Policy
10 June 2013 STEP Roundtable, 2013-0485761C6 - 2013 STEP CRA Roundtable Question 3
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| Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(3) | 139 |
Paragraph 152(4)(c)
Cases
Drautz v. The Queen, 96 DTC 6173 (FCTD)
Lornport Investments Ltd. v. The Queen, 92 DTC 6231 (FCA)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | 99 |
The Queen v. Canadian Marconi Co., 91 DTC 5626 (FCA)
Roywood Investments Ltd. v. The Queen, 79 DTC 5451, [1980] CTC 19 (FCTD), aff'd 81 DTC 5148, [1981] CTC 206 (FCA)
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| Tax Topics - Income Tax Act - Section 68 | 65 | |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | land with building was acquired only for purpose of generating capital gain | 48 |
See Also
Perfect Fry Company Ltd. v. The Queen, 2007 DTC 588, 2007 TCC 133, aff'd supra 2008 DTC 6472, 2008 FCA 218
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| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation | 73 |
Administrative Policy
19 January 1996 External T.I. 5-960062 -
30 March 1995 Internal T.I. 7-950601 -
16 September 1991 T.I. (Tax Window, No. 9, p. 11, ¶1450)
85 C.R. - Q.5
Ha v. R., 2011 TCC 271
22 March 2012 External T.I. 2011-0407731E5 - Application of Subparagraph 152(4)(b)(iii)
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii) | 163 |
Subsection 152(4.2)
Administrative Policy
8 March 2016 Internal T.I. 2015-0614421I7 - Returns filed or amended by bankrupt taxpayer
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 128 - Subsection 128(2) - Paragraph 128(2)(a) | authority of trustee to make s. 152(4.2) request does not preclude bnakrupt from doing so | 56 |