Section 220

Subsection 220(1) - Minister’s duty

Cases

The Queen v. Optical Recording Laboratories Inc., 90 DTC 6647 (FCA)

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See Also

R. v. I.R.C., Ex parte Preston, [1984] BTC 353 (C.A.)

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Subsection 220(2.1) - Waiver of filing of documents

Cases

Conocophillips Canada Resources Corp. v. Canada (National Revenue), 2016 DTC 5016 [at 6588], 2016 FC 98

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Words and Phrases
file
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Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Minister can consider reassessment without Notice of Objection 206
Tax Topics - Statutory Interpretation - French and English Version ambiguity in French version resolved through English version 212

Bul River Mineral Corporation Ltd. v. Canada (Minister of National Revenue), 2006 DTC 6048, 2006 FC 41

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Administrative Policy

9 July 2015 External T.I. 2013-0475421E5 - Section 94.2

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Tax Topics - Income Tax Act - Section 233.5 potential relief from penalties where insufficient data for computing FAPI 183
Tax Topics - Income Tax Act - Section 94.2 deemed CFA unit trust sub of a FI subject to mark-to-market rules 170
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.14) no stated accommodation for using proxy method where data unavailable 275

25 April 2014 Internal T.I. 2014-0521541I7 - Requirement for Crown corporations to file T2

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a) Crown corporations T2 exemption 0

8 October 2008 Internal T.I. 2008-0269581I7 - statute-barred refund

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Tax Topics - Income Tax Act - Section 164 - Subsection 164(1.5) "may" establishes CRA discretion 116
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) request to extend filing deadline or re-appropriate 94
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3) request to extend filing deadline 64
Tax Topics - Income Tax Act - Section 221.2 - Subsection 221.2(1) request to re-appropriate 82

Subsection 220(3) - Extensions for returns

Cases

Binder Capital Corp v. Canada (National Revenue), 2017 FC 642

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Tax Topics - Income Tax Act - Section 129 - Subsection 129(1) Federal Court lacks jurisdiction to overturn CRA decision not to extend s. 129(1) refund-claim deadline 245

Kutlu v. Canada, 2013 DTC 5137 [at 6239]

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See Also

Hughes v. The Queen, 2017 TCC 95 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 162 - Subsection 162(2) no penalty if return filed within period demanded 261
Tax Topics - Statutory Interpretation - French and English Version more lenient French version of the repeated-failure-to-file penalty in s. 162(2) preferred to English version 85

Administrative Policy

8 October 2008 Internal T.I. 2008-0269581I7 - statute-barred refund

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1.5) "may" establishes CRA discretion 116
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) request to extend filing deadline or re-appropriate 94
Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) request to extend filing deadline 64
Tax Topics - Income Tax Act - Section 221.2 - Subsection 221.2(1) request to re-appropriate 82

12 July 2013 Internal T.I. 2013-0487181I7 - Extension of the reassessment period

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Subsection 220(3.1) - Waiver of penalty or interest

Cases

Muir v. Canada (National Revenue), 2016 FC 362

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Kotel v. Canada (Attorney General), 2013 DTC 5166 [at 6421], 2013 FC 1015

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Suissa v. Canada (Attorney General), 2013 DTC 5158 [at 6383], 2013 FC 897

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Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) penalties on six family members were reasonable but probably unjust 186

Cogesco Services Limited v. Canada (Attorney General), 2014 DTC 5026 [at 6661], 2013 FC 1238

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Canada v. Guindon, 2013 DTC 5133 [at 6117], 2013 FCA 153, aff'd supra

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NRT Technology Corp v. Canada (Attorney General), 2013 DTC 5056 [at 5816], 2013 FC 200

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3563537 Canada inc. v. Canada Revenue Agency, 2013 DTC 5025 [at 5622], 2012 FC 1290

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T & S First Choice Renovations Limited v. Canada Revenue Agency, 2012 DTC 5152 [at 7377], 2012 FC 1146

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Taylor v. Canada (National Revenue), 2012 DTC 5141 [at 7315], 2012 FC 994

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Mytting v. Canada (National Revenue), 2012 DTC 5084 [at 6996], 2012 FC 465

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Spence v. Canada Revenue Agency, 2012 DTC 5061 [at 6872], 2012 FCA 58

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Toastmaster Inc. v. Canada (National Revenue), 2012 DTC 5008 [at 6555], 2011 FC 1309, aff'd 2013 DTC 5017 [at 5601], 2012 FCA 317

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Stemijon Investments Ltd. v. Canada (Attorney General), 2011 DTC 5169 [at 6250], 2011 FCA 299

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Bozzer v. Canada, 2011 DTC 5106 [at 5922], 2011 FCA 186

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Vested Rights 110

Jaka Holdings Ltd. v. Canada Revenue Agency, 2011 DTC 5081 [at 5831], 2011 FC 518

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Bozzer v. Canada, 2010 DTC 5025 [at 6612], 2010 FC 139, rev'd 2011 DTC 5106 [at 5922], 2011 FCA 186

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Canada Revenue Agency v. Telfer, 2009 DTC 5697, 2009 FCA 23

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Vitellaro v. Canada (Customs and Revenue Agency), 2005 DTC 5275, 2005 FCA 166

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Johnston v. The Queen, 2003 DTC 5494 (FCA)

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Montgomery v. MNR, 94 DTC 6367 (FCTD), aff'd 95 DTC 5032 (FCA)

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Tax Topics - General Concepts - Transitional Provisions 113

Hillier v. Attorney General of Canada, 2000 DTC 6627 (FCTD)

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See Also

Canada (National Revenue) v. Sifto Canada Corp., 2014 DTC 5083 [at 7090], 2014 FCA 140

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Knight v. The Queen, 2012 DTC 1144 [at 3300], 2012 TCC 118 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(1) penalties would have been less for more blameworthy conduct 177

Sherry v. Canada (National Revenue), 2011 DTC 5168 [at 6247], 2011 FC 1208

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Meier v. Canada Revenue Agency, 2011 DTC 5127 [at 6071], 2011 FC 840

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Yachimec v. Canada (National Revenue), 2011 DTC 5014 [at 5575], 2010 FC 1333

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Fleet v. Canada (Attorney General), 2010 DTC 5094 [at 6912], 2010 FC 609

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Cayer v. Canada Revenue Agency, 2009 DTC 5191 [at 6278], 2009 FC 1195

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Iszcenko v. The Queen, 2009 DTC 794, 2009 TCC 229 (Informal Procedure)

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Laflamme v. Canada (National Revenue), 2010 DTC 5070 [at 6794], 2008 FC 1403

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Comeau v. CCRA, 2008 DTC 6248, 2005 DTC 5489

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Bremer v. Canada (Attorney General), 2006 DTC 6125, 2006 FC 91

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Lund v. Canada (Attorney General), 2006 DTC 6367, 2006 FC 640

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Cole v. Canada (Attorney General), 2005 DTC 5667, 2005 FC 1445

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Babin v. Canada (Customs and Revenue Agency), 2005 DTC 5414, 2005 FC 972

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Karia v. Canada (Minister of National Revenue), 2005 DTC 5282, 2005 FC 639

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HealthSmith Medical Inc. v. Canada (Minister of National Revenue), 2005 DTC 5138, 2005 FC 239

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Galetzka v. Canada (Minister of Customs and Revenue), 2004 DTC 6472, 2004 FC 672

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Vitellaro v. Canada (Customs and Revenue Agency), 2004 DTC 6362, 2004 FC 561

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Miller v. Canada(Customs & Revenue Agency), 2004 DTC 6057, 2004 FC 46

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Heels v. Canada (Attorney General), 2003 DTC 5712, 2003 FC 1346 (FCTD)

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Maarsman v. Canada (Customs and Revenue Agency), 2003 DTC 5677, 2003 FC 1234

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Brickenden v. CCRA, 2003 DTC 5559 (FCTD)

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Chriscon Investments Ltd. v. Attorney General of Canada, 2003 DTC 5332 (FCTD)

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Netupsky v. The Queen, 2003 DTC 5324 (FCTD)

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Robertson v. MNR, 2003 DTC 5068 (FCTD)

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Metro-Can Construction Ltd. v. The Queen, 2002 DTC 7528 (FCTD)

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Salomon v. Deputy Attorney General of Canada, 2002 DTC 7525 (FCTD)

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Chapman v. MNR, 2002 DTC 2148 (FCTD)

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Cheng v. The Queen, 2001 DTC 5575 (FCTD)

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Robertson v. MNR, 2001 DTC 5465 (FCTD)

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Moffett Estate v. MNR, 2001 DTC 5284 (FCTD)

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Bilida v. MNR, 97 DTC 5041 (FCTD)

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Catahan v. MNR, 95 DTC 5496 (FCTD)

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Kaiser v. The Queen, 95 DTC 5187 (FCTD)

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Guimont v. MNR, 94 DTC 6227 (FCTD)

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Towers v. The Queen, 94 DTC 6118 (FCTD)

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Floyd Estate v. MNR, 93 DTC 5499 (FCTD)

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Administrative Policy

June 2017 Draft Information Circular - IC00-1R6 - Voluntary Disclosures Program

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22 February 2017 Government Response to the Sixth Report of the Standing Committee on Finance entitled: The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions

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10 June 2016 STEP Roundtable Q. 6, 2016-0641461C6 - Trust Instalment Requirements

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Tax Topics - Income Tax Act - Section 156 - Subsection 156(1) inter vivos trusts not assessed interest for inadequate instalment payments 63

May 2016 Alberta CPA Roundtable, Q.4

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(1) no penalty relief for pre-2015 years based on the more lenient 2015 calculation 58

May 2016 Alberta CPA Roundtable, Q.17

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) onus on CRA re assessing T1135 penalties outside normal statute-barring periods 57
Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) penalty not an absolute liability penalty 87

May 2016 Alberta CPA Roundtable, Q.13

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Tax Topics - Income Tax Act - Section 163.2 - Subsection 163.2(4) penalty relief standards for gross negligence also applicable to culpable conduct 97

May 2016 Alberta CPA Roundtable, Q.11

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9 October 2015 APFF Financial Strategies and Financial Instruments Roundtable Q. 4, 2015-0588971C6 F - T1135 and voluntary disclosure

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Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) CRA is studying whether the $2,500 penalty for late T1135 filings applies automatically 69

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

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16 June 2014 STEP Roundtable, 2014-0523021C6 - Multiple assessments - STEP Q19

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16 June 2014 STEP Roundtable, 2014-0530571C6 - Voluntary Disclosures - Q13

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18 September 2013 Internal T.I. 2013-0487871I7 - Filing Due Date for Elections

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30 October 2012 Ontario CTF Roundtable, 2012-0462921C6 - Ontario CTF - 163(1) Penalty

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3 June 2011 STEP Roundtable Q. 14, 2011-0401921C6 - 2011 STEP Conference - Q14 - Voluntary Disclosure

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IC00-1R3 "Voluntary Disclosures Program" March 21, 2013

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10 November 1994 Memorandum 942144 (C.T.O. "Reassessment to Reduce Penalty under Fairness Legislation")

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Halifax Round Table, February 1994, Q. 14

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IC 92-2 "Guidelines for the Cancellation and Waiver of Interest and Penalties"

Articles

Joint Committee, "Proposed Changes to the Voluntary Disclosure Program Announced June 9, 2017", 8 August 2017 Joint Committee Submission to Finance respecting the Voluntary Disclosure Program (“VDP”)

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Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper

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Ryan Rabinovitch, Angelo Discepola, "Solving Sales Tax Non-compliance Through the Canadian Voluntary Disclosure Program"

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Tax Topics - Excise Tax Act - Section 281.1 - Subsection 281.1(1) 380

Michael H. Lubetsky, "Interest Relief under the Federal and Provincial Regimes", Tax Litigation (Federated Press), Vol. XX, No. 1, 2015, p. 1182

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Esmail Bharwani, "Voluntary Disclosures", CGA Magazine, March – April, 2014, p. 48.

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David H. Sohmer, "Taxpayers May Be Penalized for Failing to Obtain a Second Opinion (Seriously!)", The Canadian Taxpayer, Vol. xxxiii No. 24, December 2011, p. 185: critique of Stemijon case.

Arthur Drache, "Sherman Letter To Finance Banks Case For 10-Year Rule Change", The Canadian Taxpayer, 3 March, 2009, VOL. XXXI, No. 5, p. 33.

Barbara Dombek, Shashi Fernando-Eden, "The ABCs of the VDP", CA Magazine, April 2003, p. 32: discussion of federal and provincial administrative positions on voluntary disclosure.

Landay, "How Fair is the Fairness Package?", Tax Profile, November 1994, p. 169: Includes a description of 12 successful and unsuccessful submissions that have been made under the fairness package to Revenue Canada.

Skulski, "Tax Collection in Recessionary Times", 1992 Conference Report, c.8

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

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 0

Subsection 220(3.2) - Late, amended or revoked elections

Cases

McNabb Family Trust v. The Queen, 98 DTC 6001 (FCA)

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See Also

Toronto Dominion Bank v. B.C. (Commissioner of Income Tax), 2017 BCCA 159

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Section 27 - Subsection 27(4) filing deadline period started being counted from the day following the year end 249
Tax Topics - Income Tax Act - Section 37 - Subsection 37(11) May 1, 2014 was not within 18 months of year-end October 31, 2012 56

Administrative Policy

21 April 2015 Internal T.I. 2014-0560811I7 - FACL carryback – Surplus & PAS election

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(2) - Paragraph 5901(2)(b) no relief for late-filed Reg. 5901(2)(b) election 164
Tax Topics - Income Tax Regulations - Regulation 5903.1 - Subsection 5903.1(1) FACL carryback from transitional year 140
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Net Earnings surplus pools are not to be retroactively adjusted for a FACL carryback 153
Tax Topics - Income Tax Regulations - Regulation 600 no relief for late-filed Reg. 5901(2)(b) election 50

27 August 2014 External T.I. 2014-0529221E5 F - Changement de méthode pour déclarer un gain

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Words and Phrases
determinable
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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) no reassessment to retroactively adopt a different earn-out recognition 134

22 August 2014 External T.I. 2014-0541171E5 - Late 45(2) Election filed by executer

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(2) late s. 45(2) election filed by executor 88

18 February 1999 T.I. 982563

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Tax Topics - General Concepts - Rectification & Rescission 30

Subsection 220(3.5) - Penalty for late filed, amended or revoked elections

Administrative Policy

9 November 2012 CTF Atlantic Roundtable, 2012-0465981C6 - CTF Atlantic - Filing Electronically

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Subsection 220(4.5) - Security for departure tax

Administrative Policy

18 October 2016 External T.I. 2015-0608051E5 F - Emigration of a trust

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Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) Fundy Settlement test may differ from residence of trustees 74

5 October 2012 APFF Roundtable, 2012-0454231C6 F - Garantie pour impôt de départ

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Subsection 220(4.51)

Articles

Jenny Yu, "Departure Tax for Small Trusts", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 8

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