Tax Controversy and Dispute Resolution: Tax Memo

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CRA Reassessments After the Normal Reassessment Period

Several recent court cases have revisited the circumstances in which the Canada Revenue Agency (CRA) is entitled to reassess a taxpayer after the normal reassessment period based on the presence of misrepresentation or a transaction with a non-arm’s length non-resident.

As important as the specific decisions, the number of these types of cases raises some concern that the CRA may be broadening its assessing practices and policies with respect to challenging statute-barred years as part of an increased focus on aggressive tax planning. A brief review of some of the recent decisions provides some insight into the context in which these practical concerns may arise.

Read this Tax Memo to get the background and our Tax Controversy and Dispute Resolution group’s observations.