Words and Phrases - "assessment"

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Iris Technologies Inc. v. Canada, 2024 SCC 24

Summary Under
Tax Topics - Excise Tax Act - Section 296 - Subsection 296(1)
assessment is a non-discretionary number

Before confirming that the taxpayer’s Federal Court motion for judicial review had represented an impermissible collateral attack on assessments...

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Words and Phrases
assessment

Dow Chemical Canada ULC v. Canada, 2024 SCC 23

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1)
assessment is a product and does not reference the process in arriving at it

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...

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Words and Phrases
assessment

Pure Spring Co. Ltd. v. MNR, 2 DTC 844 (Ex. Ct.)

Summary Under
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1)
assessment is not the piece of paper, and fixes the liability

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...

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Words and Phrases
assessment

Canada v. 984274 Alberta Inc., 2020 FCA 125

Summary Under
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1)
nil assessment was an “assessment” giving rise to an s. 164(3.1) overpayment

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...

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Words and Phrases
assessment nil assessment

Beggs v. The Queen, 2016 TCC 11 (Informal Procedure)

Summary Under
Tax Topics - Income Tax Act - Section 169 - Subsection 169(1)
refusal to grant Reg. 105 waiver not an assessment/remedy in Federal Court

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...

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Words and Phrases
assessment

Okalta Oils Ltd. v. Minister of National Revenue, 55 DTC 1176, [1955] CTC 271, [1955] S.C.R. 824

Summary Under
Tax Topics - Income Tax Act - Section 169

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...

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Words and Phrases
assessment

The Queen v. Consumers' Gas Co. Ltd., 87 DTC 5008, [1987] 1 CTC 79 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1)
assessment is of dollar amount

It was indicated, obiter, that the Minister was not precluded from taking a position before the Trial Division that was inconsistent with the...

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Words and Phrases
assessment

Civil Service Co-Operative Credit Society Ltd. v. The Queen, 2001 DTC 790 (TCC)

Summary Under
Tax Topics - Income Tax Act - Section 137.1 - Subsection 137.1(10)

The taxpayer, along with other credit unions, was required to deposit with the Ontario Share and Deposit Insurance Corporation ("OSDIC") amounts...

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Words and Phrases
allocation assessment

Canada v. Anchor Pointe Energy Ltd., 2007 DTC 5379, 2007 FCA 188

Summary Under
Tax Topics - General Concepts - Onus
assumptions can be changed at confirmation stage; mixed assumptions of fact and law struck

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...

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Words and Phrases
assessment