Canadian accountant and tax lawyer David J Rotfleisch reviewed and shared his thoughts about the results of the case 4431472 Canada Inc v Canada (Attorney General) and whether the decision was unreasonable or not
“This case highlights that if a taxpayer receives a decision from the CRA that is ambiguous and open to different interpretations, the CRA’s decision may be found unreasonable and may be set aside. In this case, because the CRA did not convincingly render a final decision, the corporate taxpayer was unable to receive a notice of reassessment,” said Rotfleisch.
He added, “receiving such notice is important because taxpayers who disagree with the CRA’s notice of assessment or reassessment have 90 days from the date of issue of the notice to appeal the decision by filing a notice of objection.”
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