Subsection 152(4)

where a taxpayer claims a non-capital loss for a statute-barred year so that his GSTC is eliminated, CCRA cannot recover the overpaid GSTC

CCRA should not exercise its discretion to reassess a taxation year to allow the carryforward of a non-capital loss arising as a result of a favourable court decision

CRA could, but is not required, to amend a statute-barred year to replace an inventory with a capital gain

refunds not issued beyond Objection period based on favourable judgment rendered to another taxpayer

notices reiterating Part IV and I tax balances from previous notices were not reassessments

a federal assessment of a return with no mention of an agreeing province starts the normal reassessment period running for that province

CRA’s assessing listed taxable RRSPs in a T3GR global return was not of the taxpayer’s (also listed) RRSP /inappropriate reliance in legal opinion on certificate of fact was carelessness

subsequent years could be reassessed to deny the carryforward of a capital loss reported in a statute-barred year

no extension under Bill-20 (re COVID) beyond December 31, 2020

nil assessment not subject to 3-year limitation in s. 152(4)