Section 165

Table of Contents

Section 165
Subsection 165(1) - Objections to assessment
Cases(16)
See Also(17)
Administrative Policy(9)
Articles(1)
Forms
Subsection 165(1.1) - Limitation of right to object to assessments or determinations
Cases(2)
Articles(1)
Subsection 165(1.2) - Limitation on objections
Cases(1)
See Also(1)
Subsection 165(1.11) - Objections by large corporations
Cases(2)
See Also(1)
Subsection 165(2) - Service
See Also(2)
Subsection 165(3) - Duties of Minister
Cases(9)
See Also(7)
Administrative Policy(8)
Subsection 165(5) - Validity of reassessment
Cases(1)
See Also(3)
Subsection 165(6) - Validity of notice of objection
Cases(1)
Subsection 165(7) - Notice of objection not required
Cases(5)
See Also(1)

Subsection 165(1) - Objections to assessment

Cases

ConocoPhillips Canada Resources Corp. v. Canada (National Revenue), 2016 DTC 5016 [at 6588], 2016 FC 98, 2017 FCA 243 rev'd

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Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) discretion under s. 220(2.1) to waive filing a Notice of Objection 474
Tax Topics - Statutory Interpretation - French and English Version ambiguity in French version resolved through English version 222

Jones v. Canada (Minister of National Revenue), 2004 DTC 6185, 2004 FC 382

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Words and Phrases
serve

Boucher v. Canada, 2004 DTC 6085, 2004 FCA 47

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Tax Topics - Income Tax Act - Section 222 Tax Court lacked jurisdiction to consider whether tax at issue had been withheld 64

870 Holdings Ltd. v. Canada, 2004 DTC 6001, 2003 FCA 460

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Canada v. Carlson, 2002 DTC 6893, 2002 FCA 145

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Chevron Canada Resources Ltd. v. MNR, 99 DTC 5648 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1.1) 175

Liampat Holdings Ltd. v. The Queen, 96 DTC 6020 (FCTD)

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Water's Edge Village Estates (Phase II) Ltd. v. The Queen, 94 DTC 6284 (FCTD)

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Mackenzie v. The Queen, 93 DTC 5291 (FCTD)

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Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) 86

495187 Ontario Ltd. v. The Queen, 92 DTC 6311 (FCTD), aff'd sub nomine The Queen v. Sarraf, 93 DTC (FCA)

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City Centre Properties Inc. v. The Queen, 91 DTC 5083 (FCA)

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Re Norris, 89 DTC 5493 (Ont CA)

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) 25

Starlite Bottlers Ltd. v. The Queen, 88 DTC 6272, [1988] 2 CTC 60 (FCTD)

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Irving Oil Ltd. v. The Queen, 88 DTC 6138, [1988] 1 CTC 263 (FCTD), aff'd 91 DTC 5106 (FCA)

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The Queen v. B. & J. Music Ltd., 80 DTC 6219, [1980] CTC 287 (FCTD)

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Smerchanski v. Minister of National Revenue, 76 DTC 6247, [1976] CTC 488, [1977] 2 S.C.R. 23

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See Also

La Mancha Group International B.V. v Commissioner of Taxation, [2020] FCA 1799

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(8.2) absorptive merger of Dutch into Lux company entailed a transfer of all assets and liabilities by operation of law 268

Ihama-Anthony v. The Queen, 2018 TCC 262

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Tax Topics - Income Tax Act - Section 166.2 - Subsection 166.2(5) - Paragraph 166.2(5)(a) taxpayer’s pre-reassessment fax to CRA could have qualified as an objection with words of objection and proper addressee, but he was now too late 184

Estate of Winifred Straessle v. The Queen, 2018 TCC 144

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Words and Phrases
heir
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Person person includes an heir of the person irrespective of also being a legal representative 232

Shreedhar v. The Queen, 2016 TCC 254 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) assessment with interest is not a nil assessment 35

Persaud v. The Queen, 2014 DTC 1031 [at 2682], 2013 TCC 405

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Newfoundland Transshipment Limited v. The Queen, 2013 DTC 1111, 2013 TCC 259

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 166.1 no obligation to reassess amended return 88

Anonby v. The Queen, 2013 DTC 1154 [at 859], 2013 TCC 184 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) no declaration as to source deductions, or vacating of reassessment that would increase substantive liability 241

Lai Colbert v. The Queen, 2005 DTC 1449, 2005 TCC 636 (Informal Procedure)

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Windsor Management Ltd. v. The Queen, 2001 DTC 749 (TCC)

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510492 BC Ltd. v. The Queen, 2001 DTC 124 (TCC)

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Sinnott v. The Queen, 2000 DTC 2459 (TCC)

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Paris v. The Queen, 98 DTC 6072 (FCTD)

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Consoltex Inc. v. The Queen, 97 DTC 724 (TCC)

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Dudar v. The Queen, 96 DTC 1828 (TCC)

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The Queen v. B.M. Enterprises Ltd., 92 DTC 6463 (FCTD)

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Tax Topics - Income Tax Act - Section 227 - Subsection 227(10) 75

460354 Ontario Inc. v. MNR, 88 DTC 1679 (TCC)

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Le Sous-Ministre du Revenu de la Province de Quebec v. Brossard, [1984] C.A. 528

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Administrative Policy

8 March 2018 CBA Commodity Tax Roundtable, Q.6

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Tax Topics - Excise Tax Act - Section 301 - Subsection 301(1.1) a single Notice of Objection can cover multiple disputed assessments 172

May 2017 Alberta CPA Roundtable. Q.1 (plenary)

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9 October 2015 APFF Roundtable Q. 22, 2015-0598301C6 F - Extension of time to file

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S4-F7-C1 - Amalgamations of Canadian Corporations

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Tax Topics - Income Tax Act - Section 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 113
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 167
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 132
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 103
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 88
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 172
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) related party, majority and 50% group exceptions 495
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(7) successoring where non-wholly owned amalgamation 109
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 113
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 112
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 165
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 87
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 66
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 120
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 55
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 297
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 758
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 113
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 149
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 139
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 169
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 44
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 346
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 189
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 281
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 191
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 230
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 122
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 62
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 137
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 467
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 371
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 327
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 249 - Subsection 249(3) 136
Tax Topics - Income Tax Act - Section 22 - Subsection 22(1) 179

27 August 2012 Internal T.I. 2012-0435571I7 F - Opposition à une cotisation

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6 March 2012 External T.I. 2011-0420751E5 - Ability to Object to a Denial of a Dividend Refund

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December 1992 B.C. Tax Executives Institute Round Table, Q.12 (October 1993 Access Letter, p. 481)

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Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) 37

88 CPTJ - Q.25

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79 C.R. - Q.11

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Articles

Joel A. Nitikman, "Nil Assessments: The View From New Zealand", Canadian Current Tax, February 1993, p. T1

Forms

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Subsection 165(1.1) - Limitation of right to object to assessments or determinations

Cases

Sherway Centre Ltd. v. Canada, 2003 DTC 5082, 2003 FCA 26

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Chevron Canada Resources Ltd. v. MNR, 99 DTC 5648 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) 179

Articles

J.W. Galway, D.E. Spiro, "Post-Consent Reassessments - Can One Object the Second Time Around?", Tax Litigation, Vol. VI, No. 4, 1998, p. 398.

Subsection 165(1.2) - Limitation on objections

Cases

Pearce v. The Queen, 2005 DTC 199, 2005 TCC 38

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See Also

Kubbernus v. The Queen, 2009 DTC 1153, 2009 TCC 311

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Subsection 165(1.11) - Objections by large corporations

Cases

Devon Canada Corporation v. Canada, 2015 FCA 214

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Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) large corporations can appeal new issues which were rejected by CRA Appeals, and perhaps may raise new issues within 1 year of Objection 342

Bakorp Management Ltd. v. Canada, 2014 DTC 5063 [at 6870], 2014 FCA 104

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Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) new timing argument raised on appeal 339

See Also

Loblaw Financial Holdings Inc. v. The Queen, 2018 TCC 182, rev'd on s. 95(1) - investment business - (a) (arm's length conduct) grounds 2020 FCA 79

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Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Bank CFA qualified as a foreign bank since it was licensed under Barbados law as an international bank 123
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business - Paragraph (a) Barbados-licensed international bank, which used Loblaw funding to invest responsively to Loblaw considerations, conducted an offside non-arm’s length business 429
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business - Paragraph (c) employee equivalents was reduced by employee time described in s. 95(2)(b) 290
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange short-term debt securities were inventory because they were the raw material for generating swap income 130
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) - Paragraph 152(4.01)(a) - Subparagraph 152(4.01)(a)(ii) GAAR is generally a separate matter rather than being subsumed in the allegedly-misused substantive provision 208
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) application of GAAR required the occurrence of an avoidance transaction (or series) in non-statute-barred years and the relevant previous year’s avoidance transaction did not occur as part of the series 512
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) hiring of employees 15-years previously to engage foreign bank exception to investment business definition was not part of same series as renewal of foreign bank licence 228
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) use of Barbados sub to engage in proprietary trading for Canadian parent misused the foreign bank exemption, whose purpose was promoting international competitiveness 336
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(l) purpose of s. 95(2)(l) exception was to permit non-resident subsidiaries of Canadian banks and dealers to compete internationally 190

Subsection 165(2) - Service

See Also

Jones v. The Queen, 2001 DTC 411 (TCC)

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Wichartz v. The Queen, 94 DTC 1703 (TCC)

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Subsection 165(3) - Duties of Minister

Cases

Opportunities for the Disabled Foundation v. Canada (National Revenue), 2016 FCA 94

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Words and Phrases
due dispatch
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Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Charitable Organization expending 70% of revenues on fund-raising and undue benefits inconsistent with wholly-devoted test 267
Tax Topics - Income Tax Act - Section 168 - Subsection 168(1) - Paragraph 168(1)(e) registration can be revoked for inadequate records 188

Ford v. Canada, 2015 DTC 5009 [at 5525], 2014 FCA 257

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Danada Enterprises Ltd. v. Canada (Attorney General), 2012 DTC 5083 [at 6986], 2012 FC 403

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Godsell v. The Queen, 2001 DTC 5384, 2001 FCA 196

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James v. Canada, 2001 DTC 5075 (FCA)

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Tax Topics - General Concepts - Audit Procedure 101
Tax Topics - General Concepts - Evidence 54
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) no s. 56(2) inclusion to taxpayer if recipient of the transferred property had earned it rather than the taxpayer 332

Bolton v. The Queen, 96 DTC 6413 (FCA)

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Tax Topics - Statutory Interpretation - Redundancy/reading in words right to appeal assessment because of Minister's delay would be redundant if assessment were automatically vacated 87

Ginsberg v. Canada, 96 DTC 6372, [1996] 3 CTC 63 (FCA)

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The Queen v. McBurney, 85 DTC 5433, [1985] 2 CTC 214 (FCA)

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Tucker v. The Queen, 78 DTC 6492, [1978] CTC 700 (FCTD)

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Tax Topics - Income Tax Act - Section 175 - Subsection 175(3) 11

See Also

Connolly v. The Queen, 2019 TCC 160 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 118.3 - Subsection 118.3(1) - Paragraph 118.3(1)(b) Notice of Confirmation likely should not address DTC claims for subsequent years 442

Air Canada v. ARQ, 2016 QCCA 710

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Tax Topics - Income Tax Act - Section 166.2 - Subsection 166.2(5) failure to establish due diligence 349

Godsell v. The Queen, 96 DTC 1292 (TCC)

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Schultz v. The Queen, 95 DTC 5657 (FCA)

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Yorkton Restaurant Venture Capital Corp. v. Saskatchewan (1994), 118 DLR (4th) 735 (Sask QB)

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Schultz v. The Queen, 93 DTC 953 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Agency - Agency 52

Greco v. MNR, 91 DTC 1090 (TCC)

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Administrative Policy

Collections, audit, objections and appeals: CRA and COVID-19 28 May 2020 CRA Webpage

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Tax Topics - Income Tax Act - Section 222 - Subsection 222(2) 50
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) suspension duiring COVID-19 of responding to most Objections 193

27 November 2018 CTF Roundtable Q. 6, 2018-0779901C6 - Appeal Process Update

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8 October 2010 Roundtable, 2010-0373711C6 F - Traitement des avis d'oppositions

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December 1992 B.C. Tax Executives Institute Round Table, Q.12 (October 1993 Access Letter, p. 481)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) 40

1 December 1992 Memorandum (Tax Window, No. 27, p. 8, ¶2353)

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1992 A.P.F.F. Annual Conference, Q. 14 (January - February 1993 Access Letter, p. 55)

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90 C.R. - Q61

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11 June 1990 Memorandum (September 1990 Access Letter, ¶1432)

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Subsection 165(5) - Validity of reassessment

Cases

Canada v. Anchor Pointe Energy Ltd., 2003 DTC 5512, 2003 FCA 294

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See Also

Viterra Inc v. The Queen, 2018 TCC 29

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Tax Topics - Excise Tax Act - Section 298 - Subsection 298(3) consequential ETA reassessments were subject to essentially the same limitations as under the ITA 370

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 152 - Subsection 152(4) 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

943372 Ontario Inc. v. The Queen, 2007 DTC 1051, 2007 TCC 294

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Subsection 165(6) - Validity of notice of objection

Cases

Jones v. Canada (Minister of National Revenue), 2004 DTC 6185, 2004 FC 382

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Subsection 165(7) - Notice of objection not required

Cases

Transcanada Pipelines Ltd. v. The Queen, 2001 DTC 5626, 2001 FCA 314

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O'Sullivan v. The Queen, 90 DTC 6278 (FCTD)

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Bowater Mersey Paper Co. Ltd. v. The Queen, 86 DTC 6293, [1986] 1 CTC 240 (FCTD), rev'd 87 DTC 5382, [1987] 2 CTC 159 (FCA)

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Stephens v. The Queen, 77 DTC 5418, [1977] CTC 590 (FCTD)

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The Queen v. Lambert, 74 DTC 6368, [1974] CTC 611 (FCTD), aff'd supra.

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 223 - Subsection 223(2) 58

See Also

Bennett v. The Queen, 96 DTC 1630 (TCC)

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Tax Topics - Income Tax Act - Section 162 - Subsection 162(2) 51

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