Chapter

(1) The Decisions of this Court and the Tax Court in Lacroix

From Deyab v. Canada, 2020 FCA 222 by Sambif

Concepts

  1. Distinct Requirements

    "[50]\n\nThat the facts of a particular case may support both the reassessment of statute-barred years and the assessment of gross negligence penalties is based on the comments of this Court at paragr

  2. Lacroix Findings

    "[52]\n\nIn Lacroix, this Court also noted:\n\n[30] The facts in evidence in this case are such that the taxpayer's tax return made a misrepresentation of facts, and the only explanation offered by th

  3. Deyab Comparison

    "[54]\n\nThe reference to the Minister’s burden of proof being “less under subsection 163(2) of the Act than under subsection 152(4)” would appear to be a typographical error. The Minister’s burden of

(1) The Decisions of this Court and the Tax Court in Lacroix | Deyab v. Canada, 2020 FCA 222 | Bifalgorithm | Bifalgorithm