Subsection 152(4)

Table of Contents

Subsection 152(4) - Assessment and reassessment
Cases(10)
See Also(11)
Administrative Policy(23)
Finance(1)
Articles(1)
Paragraph 152(4)(a)
Subparagraph 152(4)(a)(i)
Cases(23)
See Also(65)
Administrative Policy(15)
Articles(3)
Subparagraph 152(4)(a)(ii)
Cases(4)
See Also(13)
Administrative Policy(8)
Articles(1)
Paragraph 152(4)(b)
Cases(5)
See Also(3)
Administrative Policy(3)
Subparagraph 152(4)(b)(i)
Administrative Policy(3)
Subparagraph 152(4)(b)(iii)
See Also(2)
Administrative Policy(7)
Articles(1)
Subparagraph 152(4)(b)(iv)
Administrative Policy(2)
Paragraph 152(4)(b.2)
Administrative Policy(1)
Paragraph 152(4)(c)
Cases(5)
See Also(2)
Administrative Policy(7)
Subsection 152(4.2)
Administrative Policy(1)

Cases

Canada v. 984274 Alberta Inc., 2020 FCA 125

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Tax Topics - Income Tax Act - Section 160.1 - Subsection 160.1(1) ss. 160.1(1) and (3)’s application not subject to the issuance of a prior time-constrained reassessment 489
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) nil assessment was an “assessment” giving rise to an s. 164(3.1) overpayment 445
Tax Topics - General Concepts - Stare Decisis prior decision of the FCA that “manifestly overlooked [the] established line of cases” was not to be followed 76

9027-4218 Québec Inc. v. Canada (National Revenue), 2019 FC 785

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Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Subsection 18(12) determination not to reassess was a reviewable decision that started the 30-day period 255

6075240 Canada Inc. v. Canada (National Revenue), 2019 FC 642

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(3.1) - Paragraph 152(3.1)(b) s. 152(3.1), unlike its Quebec equivalent, does not give a taxpayer longer to respond to an arbitrary assessment than a normal assessment 176

Mammone v. Canada, 2019 FCA 45

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) s. 152(9) did not permit CRA to change the factual basis for its reassessment beyond the normal reassessment period 391

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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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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Words and Phrases
assess

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) can't change to cash method for particular year once accrual return filed 49

Abrahams [No. 1] v. MNR, 66 DTC 5451, [1966] CTC 690 (Ex Ct)

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See Also

Grenon v. The Queen, 2021 TCC 30

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Tax Topics - Income Tax Regulations - Regulation 4801 - Paragraph 4801(a) - Subparagraph 4801(a)(i) - Clause 4801(a)(i)(A) distribution of units that included significant purchases by minors and by adults who did not pay for their own units, was unlawful 757
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) purported establishment of “alter ego” MFTs through which an RRSP could invest in operating businesses was an abuse engaging GAAR 605
Tax Topics - Income Tax Act - Section 204.2 - Subsection 204.2(1.1) alleged distribution from non-qualified investment was not an over-contribution 277
Tax Topics - General Concepts - Window Dressing window-dressing is a deception about intention 312
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) non-qualified investments not “included” in trust’s income because it was never assessed 346
Tax Topics - Income Tax Act - Section 207.2 - Subsection 207.2(3) CRA’s assessment of Pt. XI.1 shown on the T3GR for all RRSPs of one type did not start the normal reassessment period for the taxpayer’s RRSP since no tax shown for it 370
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(d.2) distribution was not lawful because the issuer had not complied with the OM exemption, which was the exemption that it had chosen to rely on 291

3295036 Canada Inc. v. Agence du revenu du Québec, 2020 QCCA 1435

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) the use, in sales years later, of ACB that was stepped up in a “Quebec shuffle,” occurred as part of the same series 242

Mammone v. The Queen, 2018 TCC 24, rev'd 2019 FCA 45

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) subsequent retroactive deregistration of RPP also retroactively validated an assessment factually made on basis of plan’s invalidity 216
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) subsequent retroactive deregistration of RPP would not establish carelessness in previous return filing 197
Tax Topics - General Concepts - Effective Date subsequent deregistration of RPP retroactively validated reassessment 239
Tax Topics - Income Tax Act - Section 147.1 - Subsection 147.1(12) subsequent deregistration of RPP beyond normal reassessment period nonetheless retroactively validated reassessment 95
Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) valid assessment for transfer to an RPP that was retroactively deregistered 85

Aubrey Dan Family Trust v. Minister of Finance, 2016 ONSC 3801, aff'd 2017 ONCA 875

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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 124
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 71

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 86
Tax Topics - Income Tax Act - Section 165 - Subsection 165(5) s. 165(5) cannot be used to increase an assessment 161
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment licensed equipment internally transferred in one-off transaction 184

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 149
Tax Topics - Income Tax Act - Section 241 s. 241 does not override implied undertaking rule 153
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Act - Section 17.2 time of commencement of appeal 150

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 169 315

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 298
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) no further reassessment permitted if order to vacate or vary 183

Administrative Policy

15 September 2020 IFA Roundtable, Q.4

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Tax Topics - Treaties - Income Tax Conventions - Article 26 COVID-19 has not changed Treaty time limitations 155

1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement

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Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) no s. 7(3)(b) prohibition where at employer’s option to settle PSPs in cash or in shares 250
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) s. 7 rules do not apply to shares purchased through a trust 180
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Employee Benefit Plan custodial PSP arrangement was an EBP 190
Tax Topics - Income Tax Act - Section 32.1 - Subsection 32.1(1) payments made by Canco to parent for the value of parent shares distributed by parent-funded EBP to Canco employees were not deductible under s. 32.1 269
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose recharge payments made for employees participating in parent-administered PSP not deductible to extent they were employed by affiliates during vesting period 241

5 October 2018 APFF Roundtable Q. 15, 2018-0768861C6 F - Share exchange and statute of limitation

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Tax Topics - General Concepts - Effective Date retroactive ACB adjustment under PAC to statute-barred transaction may be taken into account in a current relevant transaction 59

17 April 2018 Internal T.I. 2018-0739141I7 - Amending a statute barred partnership return

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.4) CRA can treat a late request for a T5013 amendment (which cannot be dealt with under s. 152(1.4)) as a request to assess the partner returns directly 320

S3-F4-C1 - General Discussion of Capital Cost Allowance

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 207
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 65
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 431
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 152
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 229
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 317
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 221

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 460
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 251

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 97

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 125

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 58
Tax Topics - Income Tax Act - Section 162 - Subsection 162(10) normal reassessment period does not apply 138
Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) s. 152(4)(a) applies to Part XV returns 83

16 July 2013 Internal T.I. 2013-0481151I7 - Application of 152(4)(b)(iv) and 110.5

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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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7 January 2011 Internal T.I. 2010-0387011I7 F - DPA dans une année prescrite

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(a) - Revising Claims CCA claims could not be increased in “open” year to generate loss for carryback to year CRA had reassessed outside the normal reassessment period 202

31 October 1994 Internal T.I. 9412337 - REASSESSMENT OF STATUTE BARRED RETURN

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28 February 1991 T.I. 8621-4

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88 C.R. - Q.77

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84 C.R. - Q.88

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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 CCA claim can be revised where no notice of loss determination if no change in taxes payable 160

79 C.R. - Q.14

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IC75-7R3 Reassessment of a Return of Income

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Finance

3 September 2019 Comfort Letter - Deductibility of Mining Taxes

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(v) removal of statute-barring where increase in mining taxes that otherwise would be deductible under s. 20(1)(v) 174

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

Deyab v. Canada, 2020 FCA 222

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) although the taxpayer had been negligent, conduct verging on intentional acting not established 338
Tax Topics - General Concepts - Evidence adverse inference drawn from failure to call bookkeeping evidence after prima facie case made out against the taxpayer 331

Revera Long Term Care Inc. v. Canada (National Revenue), 2019 FC 239

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Ludmer v. Attorney General of Canada, 2018 QCCS 3381, aff'd 2020 QCCA 697

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) recurring fee reduction amounts received for no work were income and taxable under s. 56(2) when directed to controlled company 289
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) improper advancing of “settlement” elements that were not sustainable 45
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) equity-linked notes held in BVI company were portfolio investments held with a tax avoidance purpose, but were not subject to 7000(2)(d) interest accrual 576
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) mere possibility of locking in value accretion each year did not crystallize the maximum amount of interest respecting the year 484
Tax Topics - General Concepts - Negligence, Fiduciary Duty and Fault damages awarded against CRA for inter alia making unreasonable reassessments 260
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit recurring fee reduction amounts received for no work were income from a source 313

Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375

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Words and Phrases
misrepresentation
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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 170

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 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit contractual payments derived from Ponzi scheme were income 263
Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business taxable gains from contract with Ponzi operator 263

Lacroix v. Canada, 2008 FCA 241

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) net worth assessment 368

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)

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Nesbitt v. The Queen, 96 DTC 6045 (FCTD)

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Words and Phrases
misrepresentation

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)

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Davis v. The Queen, 84 DTC 6518, [1984] CTC 564 (FCTD)

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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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Words and Phrases
misrepresentation that is attributable to neglect
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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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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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misrepresentation

MNR v. Taylor, 61 DTC 1139 (Ex Ct)

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See Also

Hansen v. The Queen, 2020 TCC 102

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Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate annual purchase, improvement and sale of homes following their occupation was on income account 229
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) benefit of doubt should be given to taxpayer 252

Gestions Cholette Inc. v. The Queen, 2020 CCI 75

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Matthew Macisaac Consulting Inc. v. The Queen, 2020 TCC 44

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Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 58 - Subsection 58(1) refusal of request for Rule 58 determination that reporting gains as on capital rather than income account was not a “misrepresentation” 388

Demers v. Agence du revenu du Québec, 2020 QCCA 681

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Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) tax advice with clearly flawed factual assumptions did not meet a director’s due diligence defence 352

Scotti v. Agence du revenu du Québec, 2019 QCCQ 7579

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) broker-paid rebates of life insurance policy premiums are taxable under s. 12(1)(x) 446

D’Anjou v. The Queen, 2019 CCI 208

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base land ACB not increased by municipal taxes or interest 90

Mikhail v. The Queen, 2019 TCC 49 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) taxpayers could resile from their admission that they received funds from their corporation 412

Prima Properties (92) Ltd. v. The Queen, 2019 TCC 4

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Tax Topics - Excise Tax Act - Section 298 - Subsection 298(4) - Paragraph 298(4)(a) a taxpayer was not negligent in failing to ask its accountant about a change in use of its rental property 610

Mammone v. The Queen, 2018 TCC 24, rev'd 2019 FCA 45

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) RPP revocation beyond the normal reassessment period retroactively validated an unsupportable reassessment under s. 56(1)(a)(i) 414
Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) subsequent retroactive deregistration of RPP also retroactively validated an assessment factually made on basis of plan’s invalidity 216
Tax Topics - General Concepts - Effective Date subsequent deregistration of RPP retroactively validated reassessment 239
Tax Topics - Income Tax Act - Section 147.1 - Subsection 147.1(12) subsequent deregistration of RPP beyond normal reassessment period nonetheless retroactively validated reassessment 95
Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) valid assessment for transfer to an RPP that was retroactively deregistered 85

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. 9 251

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 184

Ross v. The Queen, 2013 DTC 1250 [at 1400], 2013 TCC 333

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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 69

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 112

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 126

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 111

Grossett v. The Queen, 2012 DTC 1185 [at 3465], 2012 TCC 179 (Informal Procedure)

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Mullen v. The Queen, 2012 DTC 1154 [at 3358], 2012 TCC 139 (Informal Procedure)

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9067-9051 Québec Inc., Vincent v. The Queen, 2012 DTC 1073 [at 2842], 2011 TCC 456

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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) 152

Ha v. The Queen, 2011 TCC 271

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Palardy v. The Queen, 2011 DTC 1188 [at 1050], 2011 TCC 108

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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

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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 56

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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Sljivar v. The Queen, 2009 DTC 1381 [at 2103], 2009 TCC 581

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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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Séguin Boyer v. The Queen, 2008 DTC 4891, 2008 TCC 88

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Savard v. The Queen, 2008 TCC 62

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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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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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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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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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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)

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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)

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Ver v. Canada, [1995] TCJ No. 593

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Words and Phrases
misrepresentation

Farm Business Consultants Inc. v. The Queen, 95 DTC 200 (TCC), briefly aff'd 96 DTC 6085 (FCA)

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Abogado v. The Queen, 96 DTC 3254 (TCC)

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Gauthier v. MNR, 93 DTC 758 (TCC)

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Poulin v. MNR, 87 DTC 113 (TCC)

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Markakis v. MNR, 86 DTC 1237 (TCC)

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N.D. Glazier Ltd. v. MNR, 83 DTC 48 (TRB)

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Administrative Policy

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 14, 2017-0708511C6 F - T1135 and 162(7) penalty

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Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) penalty for late-filing of a T1135 will be imposed automatically 223

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 85

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 arising after tuck under 222

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) s. 162(10) penalty for failure to file T1134s 134
Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) penalties under ss. 162(10), (10.1) or 163(2.4) for failure to file T1134s 134
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2.4) penalties for failure to file T1134s 134
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) requirements where undisclosed FAPI 212
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii) Ho acknowledged 98

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 60

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 125
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) return with substantive missing elements 61

9 November 2012 CTF Atlantic Roundtable, 2012-0465921C6 - CTF Atlantic - Statute Barred Years

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Words and Phrases
misrepresentation

21 September 2012 Internal T.I. 2012-0447401I7 - Minister's ability to reassess under 152(4)

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30 July 2012 Internal T.I. 2012-0436711I7 F - Reassessment beyond the normal reassessment period

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1 April 2010 Internal T.I. 2009-0352611I7 F - Redressement après le délai de prescription

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14 January 2010 Internal T.I. 2009-0323991I7 F - Débenture échangeable et opération à terme

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) only ½ deduction under s. 20(1)(f)(ii) for premium paid on cash-settling an exchangeable debenture under pre-2010 policy, and no s. 20(1)(f) deduction for cash settlement of forward 337
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges premium was paid on capital account in closing out a cash-settled forward entered into in order to monetize a shareholding 221
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) CRA position of applying changes in published policy prospectively 105

2 February 2005 Internal T.I. 2005-0113241I7 - Reassessment Beyond the Normal Reassessment Period

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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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Brent F. Murray, "Extending the Assessment Limitation Period", Canadian GST Monitor, No. 275, August 2011, p. 1.

Krishna, "Reassessments Based on Fraud or Misrepresentation", Canadian Current Tax, October 1992, p. A25.

Subparagraph 152(4)(a)(ii)

Cases

Mitchell v. Canada, 2002 DTC 7502, 2002 FCA 407

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Mitchell v. Attorney General of Canada, 2001 DTC 5290 (FCTD)

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Solberg v. The Queen, 92 DTC 6448 (FCTD)

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Cal Investments Ltd. v. The Queen, 90 DTC 6556 (FCTD)

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See Also

Loiselle v. Agence du revenu du Québec, 2019 QCCQ 4647

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.1) filing a revocation of a waiver confirmed that the waiver had been validly given 202

984274 Alberta Inc. v. The Queen, 2019 TCC 85, rev'd 2020 FCA 125

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) reassessment made pursuant to late waiver could not be cured by s. 152(8) 47
Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) voidness of assessment against 2nd taxpayer to a settlement agreement meant that it could not be assessed under s. 169(3) 285
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) invalid reassessment could not establish a refund amount 263
Tax Topics - Income Tax Act - Section 160.1 - Subsection 160.1(1) refund made pursuant to a void reassessment was not made pursuant to the Act (and also was not a “refund” on ordinary principles) so that s. 160.1(1) unavailable 488

Kerry (canada) Inc. v. Canada (Attorney General), 2019 FC 377

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(c) request to hold notices of objection in abeyance pending Canadian competent authority review amounted to implied waivers 486

Radelet v. The Queen, 2017 TCC 159

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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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Words and Phrases
at any time

Sljivar v. The Queen, 2009 DTC 1381 [at 2103], 2009 TCC 581

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Arpeg Holdings Ltd v. The Queen, 2007 DTC 131, 2006 TCC 593

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Brown v. The Queen, 2006 DTC 3274, 2006 TCC 381

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Chafetz v. The Queen, 2006 DTC 2119, 2005 TCC 803

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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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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 147

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 119

14 May 1991 T.I. (Tax Window, No. 3, p. 26, ¶1232)

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87 C.R. - Q.44

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87 C.R. - Q.45

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85 C.R. - Q.2

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IT-270R2 "Foreign Tax Credit", para. 14

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IC 75-7R3 "Reassessment of a Return of Income"

Articles

Pound, "Remedial Tax Planning: How to Fix It When It's Broke", 1993 Conference Report, c. 9, pp. 9:9 - 12

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Paragraph 152(4)(b)

Cases

Canada v. Agazarian, 2004 DTC 6366, 2004 FCA 32

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Words and Phrases
at any time

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)

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Paramount Productions Inc. v. The Queen, 93 DTC 5285 (FCTD)

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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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VIH Logging Ltd v. The Queen, 2004 DTC 2090, 2003 TCC 732

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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 200
Tax Topics - Income Tax Act - Section 152 - Subsection 152(3.1) normal reassessment period ends on the assessment anniversary date 39

1993 A.P.F.F. Round Table, Q.9

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20 January 1993 Memorandum Tax Window, No. 28, p. 23, ¶2393)

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Subparagraph 152(4)(b)(i)

Administrative Policy

11 October 2017 External T.I. 2016-0673171E5 - Foreign tax credit - former resident

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Tax Topics - Income Tax Act - Section 126 - Subsection 126(2.21) emigration-year return generally cannot be opened up more than 6 years later to allow a FTC for foreign tax imposed on a subsequent sale 336

11 October 2017 External T.I. 2016-0660421E5 - Foreign tax credit – former resident

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Tax Topics - Income Tax Act - Section 126 - Subsection 126(2.21) waiver cannot be used to extend period in which foreign tax must be triggered 170

9 February 2011 Internal T.I. 2010-0388491I7 F - Période de nouvelle cotisation

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Subparagraph 152(4)(b)(iii)

See Also

Ho v. The Queen, 2010 DTC 1214, 2010 TCC 325

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transaction

Shaw-Almex Industries Limited v. The Queen, 2009 DTC 1377 [at 2080], 2009 TCC 538

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Administrative Policy

30 May 2019 Internal T.I. 2019-0806761I7 - Late filing of 88(1)(d) designation

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Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation could be made for a statute-barred year that CRA was assessing within the expanded cross-border reassessment period 308

13 August 2018 Internal T.I. 2018-0763611I7 F - Subpar 152(4)(b)(iii) and FAPI

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) - Paragraph 152(4.01)(b) - Subaragraph 152(4.01)(b)(iii) reassessment of FAPI from marketable securities related to their previous contribution by the taxpayer 231

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 96

14 July 2014 Internal T.I. 2014-0537701I7 F - Voluntary disclosure - T1134 and FAPI

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) no time limitation for s. 162(10) penalty 139
Tax Topics - Income Tax Act - Section 162 - Subsection 162(10) s. 162(10) penalty for failure to file T1134s 134
Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) penalties under ss. 162(10), (10.1) or 163(2.4) for failure to file T1134s 134
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2.4) penalties for failure to file T1134s 134
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) requirements where undisclosed FAPI 212

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 208

22 March 2012 External T.I. 2011-0407731E5 - Application of Subparagraph 152(4)(b)(iii)

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Articles

Joint Committee, "Foreign Affiliate Dumping, Derivative Forward Agreement and Transfer Pricing Amendments Announced in the 2019 Federal Budget", 24 May 2019 Submission of the Joint Committee

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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 84-1 217
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) s. 110.5 addition 79

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 284

Paragraph 152(4)(b.2)

Administrative Policy

10 June 2013 STEP Roundtable, 2013-0485761C6 - 2013 STEP CRA Roundtable Question 3

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Paragraph 152(4)(c)

Cases

Kerry (canada) Inc. v. Canada (Attorney General), 2019 FC 377

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(ii) request to hold objections to subsequently nullified reassessments in abeyance constituted implied waiver 273

Drautz v. The Queen, 96 DTC 6173 (FCTD)

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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)

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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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Denelzen v. The Queen, 97 DTC 456 (TCC)

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Administrative Policy

19 January 1996 External T.I. 9600625 - ASSESSMENT OF CDA

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30 March 1995 CTF Roundtable Q. 88, 9506016 - REVISED RESOURCE ALLOWANCE CLAIMS IN CLOSED YEARS

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16 September 1991 T.I. (Tax Window, No. 9, p. 11, ¶1450)

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85 C.R. - Q.5

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Ha v. R., 2011 TCC 271

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22 March 2012 External T.I. 2011-0407731E5 - Application of Subparagraph 152(4)(b)(iii)

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21 March 2014 Internal T.I. 2013-0504491I7 - Change to loss application in a nil assessed year

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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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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 58

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