Subsection 301(1)
Administrative Policy
25 March 2021 CBA Commodity Taxes Roundtable, Q.1
CRA confirmed that where an appeal of the builder against a CRA assessment under s. 191(3) (showing an increased FMV of a new multiple unit...
Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 298 - Subsection 298(6) | CRA can consequentially assess to reduce rebates if, following an objection or appeal, it reduces a s. 191(3) assessment | 148 |
Subsection 301(1.1)
Cases
Canada v. Schafer, 2000 DTC 6542 (FCA)
The appellant had been found by the trial judge not to have received a notice of assessment. The Court found that the "sent" wording of s....
Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 334 - Subsection 334(1) | 95 | |
Tax Topics - Income Tax Act - Section 248 - Subsection 248(7) | 34 | |
Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | "deems" is irrebuttable | 68 |
Tax Topics - Statutory Interpretation - Resolving Ambiguity | 57 |
See Also
International Hi-Tech Industries Inc. v. The Queen, 2014 TCC 198
Prior to its bankruptcy, the appellant granted a general security agreement ("GSA") to its parent and related companies as security for a $6...
Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 266 - Subsection 266(2) | secured creditors able to bring claim for ITCs of bankrupt | 277 |
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 29 | secured creditors able to bring claim for ITCs of bankrupt | 324 |
Administrative Policy
8 March 2018 CBA Commodity Tax Roundtable, Q.6
- If a taxpayer is objecting to multiple Notices of Assessment, where the same issues are raised, will CRA accept a single Form GST159 with the...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) | single objection form can cover multiple GST assessments | 27 |
Forms
GST159 Notice of Objection (GST/HST)
File separate notice for each reassessment and comply with specified person particulars
File a separate form for each notice in dispute.
Specified...
Subsection 301(3)
Administrative Policy
7 April 2022 CBA Roundtable, Q.1
Where a builder objects to a reassessment that is based on the determination of a higher FMV of the property, in what situations, if any, would...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | an Appeals Officer can (and may) increase the reassessment under appeal | 66 |
25 March 2021 CBA Commodity Taxes Roundtable, Q.13
(a) Where additional documentation becomes available after an objection is with the appeals officer, must that officer review and analyze the...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | protocol for referrals by Appeals back to Audit | 174 |
Subsection 301(4)
Administrative Policy
27 February 2020 CBA Roundtable, Q.2
Regarding its policy regarding requests under s. 301(4) for the Minister to waive reconsideration of an objection, CRA stated:
On receipt of...