Section 225.1

Cases

Coombs v. Canada (National Revenue), 2013 DTC 5023 [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...

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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...

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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 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...

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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...

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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...

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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...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 224.1 usual policy not to set-off if appeal 71

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...

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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...

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