Concept

Permissive Deductions

Deyab v. Canada, 2020 FCA 222 / CRA restricts taxpayer requests to revise permissive deductions

"CRA has issued a new Circular to replace Information Circular IC75-7R3 Reassessment of a Return of Income and Information Circular IC84-1 Revision of CCA Claims and Other Permissive Deductions, both dated July 9, 1984.\n\nCRA refers to examples of permissive deductions as including CCA, SR&ED deductions and CEE, CDE and COGPE deductions; whereas deductions that are not considered permissive include charitable donations or other amounts that reduce taxable income rather than net income, tax credits and reserves, such as the capital gains reserve under s. 40(1)(a)(iii).\n\nA TPR to revise the amount of a reserve claimed in a particular taxation year will not be permitted if the reserve was based, at the time it was claimed, on what was considered to be a reasonable amount."

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Permissive Deductions | Deyab v. Canada, 2020 FCA 222 | Bifalgorithm | Bifalgorithm