Application under subsection 220(2.1) ITA Where Out of Time For Notice of Objection
The Federal Court of Canada ruled in Conocophillips Canada Resources Corp. v MNR T-1811-12 that CRA can waive the obligation to serve an income tax notice of objection under subsection 220(2.1) of the Income Tax Act. This means that in some circumstances even if the limitation period to file an Objection has been missed a Toronto tax litigation lawyer can apply to CRA to waive this requirement and in effect a late income tax objection can be processed.
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