Archive for Month: February

Eyeglasses and Documents on Desk

Case Commentary Cassidy v Canada: Using ‘Extraordinary Circumstances,’ CRA’s Delays, Inability to Pay, or Financial Hardship When Seeking Taxpayer Relief

Introduction: Mr. Cassidy’s Request for Taxpayer Relief Taxpayers may, under subsection 220(3.1) of the Income Tax Act (“Tax Act”), request relief for penalties and interest in what is referred to as a taxpayer relief application (formerly known as fairness application). Granting this application is at the Canada Revenue Agency’s...

Read More
Smartphone with Opened Calculator Lying on a Document with an Income Statement

Taxpayer Sidesteps Gross-Negligence Penalties and $90,000 in Taxable Income Because Tax Year was Statute-Barred: Abbass v The King, 2023 TCC 169

Introduction: Statute-Barred Tax Years & Statute-Barred Tax Audits Canada’s Income Tax Act sets out a “normal reassessment period,” after which the Canada Revenue Agency generally cannot reassess a person’s taxable income or tax payable. For most individual taxpayers, the normal reassessment period expires three years from the date that...

Read More