Cases
Coombs v. Canada (National Revenue), 2013 DTC 5023 [at at 5612], 2012 FC 1499
Manson J. dismissed the taxpayer's application to quash a Requirement To Pay from CRA, as challenges to the validity of a tax assessment are a...
Articles
Khashayar Haghgouyan, "Narrowing of the Collection Restrictions - Set-Off Can Occur!", CCH Tax Topics, No. 4 1901, 14 August 2008, p. 1.
Subsection 225.1(2) - No action by Minister
Cases
Cybernius Medical Ltd. v. Canada (Attorney General), 2017 FC 226
The applicant (“Cybernius”) did not file income tax returns for its 2003-2005 taxation years and, in 2006, was assessed by the Minister for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 221.2 - Subsection 221.2(1) | Minister ordered to make a taxpayer-requested s. 221.2(1) transfer between two taxpayer accounts | 413 |
Arif (Re), 2011 DTC 5173 [at at 6284], 2011 FC 1000
Shore J. granted the Minister's s. 225.1(2) application. The Court was informed that the taxpayer had been involved in cocaine trafficking, for...
Subsection 225.1(3) - Idem [No action by Minister]
Cases
Cormier v. The Queen, 91 DTC 5159 (FCTD)
S.225.1(3), which was added applicable to "notices of assessment" mailed after 1984, did not apply where a reassessment was issued in 1983, and a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Assessmen | 48 |
O'Sullivan v. The Queen, 90 DTC 6278, [1990] 1 CTC 429 (FCTD)
The taxpayer, after filing notices of objection in 1984 to reassessments by Revenue Canada, filed a Notice of Appeal to the Tax Court pursuant to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(7) | 135 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | 44 |
Administrative Policy
86 C.R. - Q.85
the filing of a bona fide objection does not delay the time for remitting taxes that have been deducted.
Subsection 225.1(4) - Idem [No action by Minister]
Administrative Policy
IC98-1R4 "Tax Collections Policies" 12 June 2013
We will accept adequate security instead of payment under some circumstances. For example, if the Tax Court of Canada or the Canadian...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 224.1 | usual policy not to set-off if appeal | 75 |
Subsection 225.1(5) - Idem [No action by Minister]
Cases
Doyle v. MNR, 89 DTC 5483, [1989] 2 CTC 270 (FCTD)
A letter of abeyance signed by a tax return preparer as agent for a taxpayer who previously had signed his notice of objection personally, was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | 125 | |
| Tax Topics - Income Tax Act - Section 221 - Subsection 221(1) - Paragraph 221(1)(f) | 51 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxpayer | 31 |
Subsection 225.1(6) - Where ss. (1) to (4) do not apply
Paragraph 225.1(6)(b)
Administrative Policy
30 January 2014 Internal T.I. 2012-0460181I7 - Application of paragraph 225.1(6)(b)
A non-resident disposes of a taxable Canadian property and files a T2062 and discloses that Part XIII tax has not been withheld and remitted with...