Words and Phrases - "overpayment"
984274 Alberta Inc. v. The Queen, 2019 TCC 85, rev'd 2020 FCA 125
refund made pursuant to a void reassessment was not made pursuant to the Act (and also was not a “refund” on ordinary principles) so that s. 160.1(1) unavailable
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 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(ii) | reassessment made pursuant to late waiver was void | 34 |
Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | reassessment made pursuant to late waiver could not be cured by s. 152(8) | 47 |
Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) | voidness of assessment against 2nd taxpayer to a settlement agreement meant that it could not be assessed under s. 169(3) | 285 |
Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) | invalid reassessment could not establish a refund amount | 263 |