Cases
Coombs v. Canada (National Revenue), 2013 DTC 5023 [at at 5612], 2012 FC 1499
Manson J. dismissed the taxpayer's application to quash a Requirement To Pay from CRA, as challenges to the validity of a tax assessment are a...
Articles
Khashayar Haghgouyan, "Narrowing of the Collection Restrictions - Set-Off Can Occur!", CCH Tax Topics, No. 4 1901, 14 August 2008, p. 1.
Subsection 225.1(2) - No action by Minister
Cases
Cybernius Medical Ltd. v. Canada (Attorney General), 2017 FC 226
The applicant (“Cybernius”) did not file income tax returns for its 2003-2005 taxation years and, in 2006, was assessed by the Minister for...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 221.2 - Subsection 221.2(1) | Minister ordered to make a taxpayer-requested s. 221.2(1) transfer between two taxpayer accounts | 413 |
Arif (Re), 2011 DTC 5173 [at at 6284], 2011 FC 1000
Shore J. granted the Minister's s. 225.1(2) application. The Court was informed that the taxpayer had been involved in cocaine trafficking, for...
Subsection 225.1(3) - Idem [No action by Minister]
Cases
Cormier v. The Queen, 91 DTC 5159 (FCTD)
S.225.1(3), which was added applicable to "notices of assessment" mailed after 1984, did not apply where a reassessment was issued in 1983, and a...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Assessmen | 48 |
O'Sullivan v. The Queen, 90 DTC 6278, [1990] 1 CTC 429 (FCTD)
The taxpayer, after filing notices of objection in 1984 to reassessments by Revenue Canada, filed a Notice of Appeal to the Tax Court pursuant to...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 165 - Subsection 165(7) | 135 | |
Tax Topics - Statutory Interpretation - Ordinary Meaning | 44 |
Administrative Policy
86 C.R. - Q.85
the filing of a bona fide objection does not delay the time for remitting taxes that have been deducted.
Subsection 225.1(4) - Idem [No action by Minister]
Administrative Policy
IC98-1R4 "Tax Collections Policies" 12 June 2013
We will accept adequate security instead of payment under some circumstances. For example, if the Tax Court of Canada or the Canadian...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 224.1 | usual policy not to set-off if appeal | 75 |
Subsection 225.1(5) - Idem [No action by Minister]
Cases
Doyle v. MNR, 89 DTC 5483, [1989] 2 CTC 270 (FCTD)
A letter of abeyance signed by a tax return preparer as agent for a taxpayer who previously had signed his notice of objection personally, was...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - General Concepts - Agency | 125 | |
Tax Topics - Income Tax Act - Section 221 - Subsection 221(1) - Paragraph 221(1)(f) | 51 | |
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxpayer | 31 |
Subsection 225.1(6) - Where ss. (1) to (4) do not apply
Paragraph 225.1(6)(b)
Administrative Policy
30 January 2014 Internal T.I. 2012-0460181I7 - Application of paragraph 225.1(6)(b)
A non-resident disposes of a taxable Canadian property and files a T2062 and discloses that Part XIII tax has not been withheld and remitted with...