Cases
Kyte v. R., 97 DTC 5022, [1997] 2 CTC 14 (FCA)
Although the amount of an assessment of the taxpayer under s. 227.1 was correct in dollar terms, the certificate issued by the Minister as...
Ginsberg v. Canada, 96 DTC 6372, [1996] 3 CTC 63 (FCA)
After noting that recent decisions have diminished the importance of the distinction between directory and mandatory provisions, Desjardins J.A....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | 21 | |
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | Minister's failure to act with all due dispatch is not a basis for vacating an assessment | 118 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 11 | 47 |
See Also
Ntakos Estate v. The Queen, 2018 TCC 224
In 2003, various T1 adjustment requests were made with CRA by the accountant (“Newton”) for deceased taxpayer (“Anna”), her brothers (now...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 166.1 - Subsection 166.1(7) - Paragraph 166.1(7)(a) | no extension necessary as reassessments were void due to taxpayer's incapacity | 204 |
Rio Tinto Alcan Inc. v. The Queen, 2017 TCC 67
After rejecting taxpayer submissions that a reassessment was invalid because it had been made before any audit of the items in question had really...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | reassessment made without a proper audit in order to beat statute-barring was valid | 612 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) | further reassessment can carryforward balances from previous reassesment not described in 152(4.01) | 248 |
Deneschuk Building Supplies Ltd. v. The Queen, 96 DTC 1467, [1996] 3 CTC 2039 (TCC)
The failure of the Minister to provide written notice before allocating business limits, as required by s. 125(4), was a substantial and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 125 - Subsection 125(3) | 155 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(7) | 50 |