Subsection 244(4) - Limitation period
Cases
PS&E Contractors Ltd. v. The Queen, 89 DTC 5067, [1989] 1 CTC 184 (Sask. C.A.)
The Queen v. Print Three, 88 DTC 6315 (Ont. Prov. Ct.)
R. v. Les Habitations Perigord Inc., 88 DTC 6267, [1988] 2 CTC 64 (Que. C.A.)
Re Pica and The Queen, 85 DTC 5041, [1985] 1 CTC 73 (S.C.O.)
James v. The Queen, 84 DTC 6570, [1984] CTC 672 (S.C.O.), rev'd by 86 DTC 6432, [1986] 2 CTC 288 (Ont CA), briefly aff'd by 88 DTC 6273, [1988] 2 CTC 1, [1988] 1 S.C.R. 669
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Paragraph 11(d) | 62 |
R. v. Simmons, 84 DTC 6171 (Nfld. Prov. Ct.)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(2) | 62 |
Fee et al. v. Bradshaw et al., 82 DTC 6264, [1982] CTC 201, [1982] 1 S.C.R. 607
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Usarco Ltd. v. A.G. Canada, 80 DTC 6308, [1980] CTC 484 (FCTD)
Medicine Hat Greenhouse Ltd. and German v. R., 79 DTC 5091, [1980] CTC 114 (Alta. C.A.)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Abuse of Process | delay in initiating a prosecution | 65 |
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 26 |
Subsection 244(5) - Proof of service by mail
See Also
Luxury Home Landscape Construction Inc. v. The Queen, 2021 TCC 4 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 335 - Subsection 335(1) | internal CRA form referencing the Canada Post tracking number did not satisfy affidavit requirement – also ambiguity as to whether notice was addressed to the corporate taxpayer | 502 |
DaSilva v. The Queen, 2018 TCC 74 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 335 - Subsection 335(6) | failure of official to confirm that the notice of assessment was included in a batch that had been accurately processed | 312 |
| Tax Topics - Excise Tax Act - Section 303 - Subsection 303(7) - Paragraph 303(7)(a) | taxpayer's testimony that she had not received a notice of assessment was credible | 166 |
| Tax Topics - Income Tax Act - Section 166.1 - Subsection 166.1(7) - Paragraph 166.1(7)(a) | testimony accepted that notice of assessment had not been received | 93 |
Hamer v. The Queen, 2014 DTC 1168 [at 3602], 2014 TCC 218
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Skalbania v. The Queen, 2009 DTC 2066, 2009 TCC 576
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 244 - Subsection 244(15) | 50 |
Subsection 244(7) - Proof of failure to comply
Cases
Cholodniuk v. R., 92 DTC 6168, [1992] 2 CTC 150 (Sask. C.A.)
Subsection 244(9) - Proof of documents
Subsection 244(10) - Proof of no appeal
See Also
Sicoli v. The Queen, 2013 DTC 1167 [at 917], 2013 TCC 207
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Poulin v. The Queen, 2013 DTC 1102 [at 545], 2013 TCC 104
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | 163 |
Carcone v. The Queen, 2012 DTC 1032 [at 2651], 2011 TCC 550
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Graham v. The Queen, 92 DTC 1012, [1991] 2 CTC 2712 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - General Concepts - Onus | 149 | |
| Tax Topics - Income Tax Act - Section 169 | 149 |
Subsection 244(13) - Proof of documents
Cases
The Queen v. Ehli, 99 DTC 6505 (Alta CA)
Swyryda v. The Queen, 81 DTC 5109 (Sask QB)
Israel v. The Queen, 79 DTC 5418, [1979] CTC 468 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 119 - Subsection 119(1) | 27 | |
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(8) | 28 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming | employee not engaged in farming business | 46 |
Subsection 244(14) - Mailing or sending date
See Also
236130 British Columbia Ltd. v. The Queen, 2006 DTC 2053, 2005 TCC 770
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.1) | 126 |
VIH Logging Ltd v. The Queen, 2004 DTC 2090, 2003 TCC 732
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 64 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) | 83 |
McIntyre v. MNR, 93 DTC 999, [1993] 2 CTC 2244 (TCC)
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(2) | 118 |
Everett's Truck Stop Ltd. v. The Queen, 93 DTC 965, [1993] 2 CTC 2658 (TCC)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | inducement to purchase product for more was includible under s. 12(1)(x), or perhaps s. 9 | 148 |
Subsection 244(15) - Date when assessment made
Cases
Skalbania v. The Queen, 2009 DTC 2066, 2009 TCC 576
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 244 - Subsection 244(5) | 111 |
McGowan v. The Queen, 95 D.T.C 5337, [1996] 1 CTC 61, [1995] 1 CTC 2978 (FCA)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 166.2 - Subsection 166.2(1) | 42 |
Subsection 244(16)
See Also
Aubrey Dan Family Trust v. Minister of Finance, 2016 ONSC 3801, aff'd 2017 ONCA 875
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Ontario - Taxation Act 2007 - Section 158 | federal form with CRA insignia purported to be a prescribed form | 364 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | original assessment not dealing with Ontario tax starts the normal Ontario reassessment period | 299 |
Subsection 244(20)
Cases
Zeifmans LLP v. Canada (National Revenue), 2021 FC 363
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| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) | an RFI issued to an accounting firm re named clients could extend to unnamed offshore entities if the latter were not being audited | 418 |
See Also
Menzies v. The Queen, 2016 TCC 73 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.6) | receipt of notice of redetermination of loss by limited partner not relevant | 150 |
Administrative Policy
18 October 2016 Internal T.I. 2016-0640321I7 - Subsections 152(1.5) and 244(20)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.5) | requirement satisfied by delivery to partnership address | 33 |