Words and Phrases - "assessment"
Iris Technologies Inc. v. Canada, 2024 SCC 24
Before confirming that the taxpayer’s Federal Court motion for judicial review had represented an impermissible collateral attack on assessments...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 18.5 | Federal Court has jurisdiction over matters of reprehensible CRA conduct (none was alleged here) | 278 |
Dow Chemical Canada ULC v. Canada, 2024 SCC 23
In rejecting the taxpayer’s position that the Minister’s decision under s. 247(10) is part of an assessment, Karirer J indicated that this...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(10) | the Tax Court lacks jurisdiction to review CRA decisions regarding s. 247(10) downward adjustments | 697 |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) - Paragraph 171(1)(b) - Subparagraph 171(1)(b)(iii) | Tax Court lacks jurisdiction to vary or quash an s. 247(10) opinion of the Minister | 128 |
Pure Spring Co. Ltd. v. MNR, 2 DTC 844 (Ex. Ct.)
In the course of finding that the exercise by the Minister of his discretion to disallow an expense was an assessment that could be appealed as...
Canada v. 984274 Alberta Inc., 2020 FCA 125
The taxpayer (“984”) reported a capital gain on its 2003 sale of land on the basis that it had acquired it from its parent (Henro) on a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 160.1 - Subsection 160.1(1) | ss. 160.1(1) and (3)’s application not subject to the issuance of a prior time-constrained reassessment | 489 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | nil assessment not subject to 3-year limitation in s. 152(4) | 190 |
| Tax Topics - General Concepts - Stare Decisis | prior decision of the FCA that “manifestly overlooked [the] established line of cases” was not to be followed | 76 |
Beggs v. The Queen, 2016 TCC 11 (Informal Procedure)
CRA determined to not grant a waiver of withholding under Reg. 105 from fees to be paid to the appellants in connection with a proposed...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) | refusal to grant Reg. 105 waiver not an assessment/remedy in FC | 84 |
Okalta Oils Ltd. v. Minister of National Revenue, 55 DTC 1176, [1955] CTC 271, [1955] S.C.R. 824
The taxpayer was not able to appeal a "nil" reassessment to the Tax Appeal Board. The word "assessment" referred to the actual sum in tax which...
The Queen v. Consumers' Gas Co. Ltd., 87 DTC 5008, [1987] 1 CTC 79 (FCA)
It was indicated, obiter, that the Minister was not precluded from taking a position before the Trial Division that was inconsistent with the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Accounting Principles | 35 | |
| Tax Topics - Income Tax Act - Section 181 - Subsection 181(3) | 78 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.1) | payments made in the same manner as by private businesses were not “government assistance” | 125 |
Civil Service Co-Operative Credit Society Ltd. v. The Queen, 2001 DTC 790 (TCC)
The taxpayer, along with other credit unions, was required to deposit with the Ontario Share and Deposit Insurance Corporation ("OSDIC") amounts...
Canada v. Anchor Pointe Energy Ltd., 2007 DTC 5379, 2007 FCA 188
The Minister initially reassessed the taxpayer on the assumption that it had purchased seismic data for more than its fair market value, so that a...