Subsection 152(4)

Table of Contents

Subsection 152(4) - Assessment and reassessment
Cases(6)
See Also(8)
Administrative Policy(19)
Articles(1)
Paragraph 152(4)(a)
Subparagraph 152(4)(a)(i)
Cases(21)
See Also(57)
Administrative Policy(12)
Articles(3)
Subparagraph 152(4)(a)(ii)
Cases(5)
See Also(9)
Administrative Policy(8)
Articles(1)
Paragraph 152(4)(b)
Cases(5)
See Also(3)
Administrative Policy(3)
Subparagraph 152(4)(b)(i)
Administrative Policy(2)
Subparagraph 152(4)(b)(iii)
See Also(2)
Administrative Policy(5)
Subparagraph 152(4)(b)(iv)
Administrative Policy(2)
Paragraph 152(4)(b.2)
Administrative Policy(1)
Paragraph 152(4)(c)
Cases(4)
See Also(2)
Administrative Policy(7)
Subsection 152(4.2)
Administrative Policy(1)

Cases

Canada v. Gray, 2008 DTC 6641, 2008 FCA 284

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Ludmer v. The Queen, 95 DTC 5311 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Regina Shoppers Mall Ltd., 91 DTC 5101 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
assess

Hadler Turkey Farms Inc. v. The Queen, 86 DTC 6013, [1986] 1 CTC 81 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) 49

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Klemen v. The Queen, 2014 DTC 1170 [at 3613], 2014 TCC 244

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 169 285

Yazdani v. The Queen, 2012 DTC 1303 [at 3983], 2012 TCC 371 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Blackburn Radio Inc. v. The Queen, 2012 DTC 1213 [at 3580], 2012 TCC 255

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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 306

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 476
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 669
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 170
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 248
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 194
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 178
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 145
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 184
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 267
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 60
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 140
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 167
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 53
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 204
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 150
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 55
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 142
Tax Topics - Income Tax Act - Section 68 153
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 117
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 403
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 207
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 214
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 191

29 July 2015 Internal T.I. 2015-0575921I7 - Recapture arising in statute-barred years

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

14 April 2014 External T.I. 2014-0521341E5 - Unclaimed interest expense

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

7 February 2014 Internal T.I. 2013-0512601I7 - Clarification of 2013-0481151I7

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

12 December 2013 Internal T.I. 2013-0497231I7 - Penalties on Foreign Asset Reporting

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

25 March 2013 Internal T.I. 2013-0474111I7 - Amendment to Prior Years' CCA

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

11 December 2012 Internal T.I. 2012-0459341I7 - Adjustments Beyond Normal Reassessment Period

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

31 October 1994 Memorandum 941233

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(3.1) 35

28 February 1991 T.I. 8621-4

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 C.R. - Q.77

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

84 C.R. - Q.88

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IC 84-1 "Revision of Capital Cost Allowance Claims and Other Permissive Deductions"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

79 C.R. - Q.14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IC75-7R3 Reassessment of a Return of Income

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Beith, "Fairness Package", 1992 Conference Report, c.7.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) 0

Paragraph 152(4)(a)

Subparagraph 152(4)(a)(i)

Cases

Ludmer v. Attorney General of Canada, 2018 QCCS 3381

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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 275
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) improper advancing of “settlement” elements that were not sustainable 43
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 540
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 454
Tax Topics - General Concepts - Negligence and Fiduciary Duty damages awarded against CRA for inter alia making unreasonable reassessments 252
Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit recurring fee reduction amounts received for no work were income from a source 299

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
misrepresentation
Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Middlebrook v. Canada, 2013 DTC 5001 [at 5501], 2012 FCA 264

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Canada v. Johnson, 2013 DTC 5004 [at 5515], 2012 FCA 253

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) net worth assessment 352

Gebhart v. Canada, 2008 DTC 6581, 2008 FCA 206

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Ridge Run Developments Inc. v. The Queen, 2007 DTC 734, 2007 TCC 68

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Naguib v. Canada, 2004 DTC 6082, 2004 FCA 40

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Can-Am Realty Ltd. v. The Queen, 97 DTC 5070 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
misrepresentation

Can-Am Realty Ltd. v. The Queen, 94 DTC 6293 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 95

1056 Enterprises Ltd. v. The Queen, 89 DTC 5287 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Patricio v. The Queen, 84 DTC 6413 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 99

Venne v. The Queen, 84 DTC 6247, [1984] CTC 223 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
misrepresentation that is attributable to neglect
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 67

Reilly Estate v. The Queen, 84 DTC 6001, [1984] CTC 21 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

MNR v. Bisson, 72 DTC 6374 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
misrepresentation

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Mammone v. The Queen, 2018 TCC 24

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) RPP revocation beyond the normal reassessment period retroactively validated an unsupportable reassessment under s. 56(1)(a)(i) 398
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 200
Tax Topics - General Concepts - Effective Date subsequent deregistration of RPP retroactively validated reassessment 223
Tax Topics - Income Tax Act - Section 147.1 - Subsection 147.1(12) subsequent deregistration of RPP beyond normal reassessment period nonetheless retroactively validated reassessment 91
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 83

Thompson v. The Queen, 2017 TCC 115

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Mont-Bruno C.C. Inc. v. The Queen, 2016-1152(IT)G, 21 March 2017

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Francis & Associates v. The Queen, 2014 DTC 1146 [at 3468], 2014 TCC 137 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

832866 Ontario Inc. v. The Queen, 2014 TCC 93 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Bandula v. The Queen, 2013 DTC 1225 [at 1238], 2013 TCC 282

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Lenneville v. The Queen, 2013 DTC 1196 [at 1045], 2013 TCC 56

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Schmidt v. The Queen, 2013 DTC 1063 [at 337], 2013 TCC 11

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

D'Andrea v. The Queen, 2011 DTC 1234 [at 1356], 2011 TCC 298

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 146

Ha v. The Queen, 2011 TCC 271

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Cameron v. Queen, 2011 DTC 1166 [at 914], 2011 TCC 107

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Stanislao Calandra o/a Calandra Hair Studio v. The Queen, 2011 DTC 1049 [at 142], 2011 TCC 7 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Misiak v. The Queen, 2011 DTC 1048 [at 237], 2011 TCC 1 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Labow v. The Queen, 2010 TCC 408, 2010 DTC 1282 [at 3956], aff'd 2012 DTC 5001 [at 6501], 2011 FCA 305

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Chaumont v. The Queen, 2010 DTC 1014 [at 2599], 2009 TCC 493 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Donato v. The Queen, 2009 DTC 1384 [at 2111], 2009 TCC 590

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Wachsmann v. The Queen, 2009 TCC 420

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

College Park Motor Products Ltd. v. The Queen, 2009 DTC 1469, 2009 TCC 409

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Dalphond v. The Queen, 2009 DTC 1395, 2008 TCC 427, aff'd 2010 DTC 5016 [at 6589], 2009 FCA 121

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

O'Dea v. The Queen, 2009 DTC 912, 2009 TCC 295

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Savard v. The Queen, 2008 TCC 62

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Abakhan & Associates Inc. v. Canada (Attorney General), 2008 DTC 6028, 2007 FC 1327

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Mensah v. The Queen, 2008 DTC 4358, 2008 TCC 378

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

McKellar v. The Queen, 2007 DTC 1007, 2007 TCC 266

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Peek v. The Queen, 2007 DTC 602, 2007 TCC 152

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Petric v. The Queen, 2006 DTC 3082, 2006 TCC 306

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

S.E.R. Contracting Ltd. v. The Queen, 2006 DTC 2212, 2006 TCC 6 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Succession de Feu Cléophas Saint-Aubin c. La Reine, 2005 DTC 912, 2003 TCC 608

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Riordan v. The Queen, 2005 DTC 397, 2005 TCC 150

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Central Interior Incorporated v. The Queen, 2005 DTC 144, 2004 TCC 725

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Jencik v. The Queen, 2004 TCC 295 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Sidhu v. The Queen, 2004 DTC 2540, 2004 TCC 174

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Produits Forestiers St-Armand Inc. c. La Reine, 2004 DTC 2494, 2003 TCC 696

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Snowball v. The Queen, 97 DTC 512 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Farina v. The Queen, 97 DTC 487 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 47

Prévost v. MNR, [1996] 1 CTC 2701 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
misrepresentation

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Gauthier v. MNR, 93 DTC 758 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Poulin v. MNR, 87 DTC 113 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Markakis v. MNR, 86 DTC 1237 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) penalty for late-filing of a T1135 will be imposed automatically 206

May 2016 Alberta CPA Roundtable, Q.17

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

30 June 2014 Internal T.I. 2013-0508411I7 F - Part IV Tax and the Dividend Refund

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 186 - Subsection 186(1) when to stop circular calculation for cross dividends arising after tuck under 216

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 162 - Subsection 162(10) s. 162(10) penalty for failure to file T1134s 132
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 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
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii) Ho acknowledged 88

5 June 2014 Internal T.I. 2013-0509051I7 - Penalties beyond the Normal Reassessment Period

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
misrepresentation

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2 February 2005 Internal T.I. 2005-011324 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Radelet v. The Queen, 2017 TCC 159

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Remtilla v. The Queen, 2015 TCC 200

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Rémillard v. The Queen, 2011 DTC 1286 [at 1617], 2011 TCC 327

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
at any time

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Villeneuve v. The Queen, 2004 DTC 2258 (TCC), rev'd 2004 DTC 6077 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 75

Mierins v. The Queen, 96 DTC 1140 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 84

Loukras v. MNR, 90 DTC 1557 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

15 June 2015 Internal T.I. 2015-0583081I7 - Refund Request - Normal Reassessment Period

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

87 C.R. - Q.44

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

87 C.R. - Q.45

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

85 C.R. - Q.2

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 152(4)(b)

Cases

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
at any time

Clibetre Exploration Ltd. v. Canada (Minister of National Revenue), 2003 DTC 5073, 2003 FCA 16

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Agazarian v. The Queen, 2003 DTC 435 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Placer Dome Inc. v. The Queen, 91 DTC 5115 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Papiers Cascades Cabano Inc. c. La Reine, 2006 DTC 2305, 2005 TCC 396

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

10 March 2016 Internal T.I. 2015-0614161I7 - Extended reassessment period 152(4)(b)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subparagraph 152(4)(b)(i)

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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 320

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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 164

Subparagraph 152(4)(b)(iii)

See Also

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
transaction

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

16 January 2017 Internal T.I. 2016-0651411I7 - Reassessment period – transfer pricing

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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 132
Tax Topics - Income Tax Act - Section 162 - Subsection 162(10) s. 162(10) penalty for failure to file T1134s 132
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 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

22 April 2013 Internal T.I. 2013-0478121I7 - Application of 152(4)(b)(iii)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 December 2012 Internal T.I. 2012-0439301I7 F - Reassessment beyond the normal reassessment period

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subparagraph 152(4)(b)(iv)

Administrative Policy

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 152(4)(c)

Cases

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Lornport Investments Ltd. v. The Queen, 92 DTC 6231 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) 99

The Queen v. Canadian Marconi Co., 91 DTC 5626 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Roywood Investments Ltd. v. The Queen, 79 DTC 5451, [1980] CTC 19 (FCTD), aff'd 81 DTC 5148, [1981] CTC 206 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

19 January 1996 External T.I. 5-960062 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

30 March 1995 Internal T.I. 7-950601 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

85 C.R. - Q.5

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Ha v. R., 2011 TCC 271

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 152(4.2)

Administrative Policy

8 March 2016 Internal T.I. 2015-0614421I7 - Returns filed or amended by bankrupt taxpayer

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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

Navigation