Section 221.2

Administrative Policy

20 November 2017 CTF Annual Conference - CRA Panel on Issues in the Administration and Enforcement of the ITA, Q.10

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18 July 2013 External T.I. 2012-0463421E5 - Section 221.2

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4 March 2011 External T.I. 2010-0384921E5 - Overpayment of tax.

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Subsection 221.2(1) - Re-appropriation of amounts

Cases

Referred Realty Inc. v. Canada (Attorney General), 2018 FC 59

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Cybernius Medical Ltd. v. Canada (Attorney General), 2017 FC 226

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 225.1 - Subsection 225.1(2) valid notice of objection was still outstanding: garnishment amount to be returned 379

Clover International Properties Ltd. v. Canada (AG), 2013 DTC 5116 [at 6132], 203 FC 676

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) 185

Administrative Policy

8 September 2014 External T.I. 2013-0482991E5 - 15(2) and related provisions

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.11) novation of pre-2012 loan 164
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) assignment of debt not its repayment 135

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 220 - Subsection 220(3) request to extend filing deadline 64

Subsection 221.2(2)

Cases

Pomeroy’s Masonry Limited v. Canada (Attorney General), 2017 FC 952

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