Chapter
II. Decision of the Tax Court
From Deyab v. Canada, 2020 FCA 222 by Sambif
Concepts
- Shareholder Benefits
"Mr. Deyab does not dispute that he and his family received the amounts indicated above from M.D. Consulting. However it was, and remains, his position that he was simply withdrawing money that he had
- Statute-barred Years
"The “statute-barred years” are those that were reassessed after the expiration of the normal reassessment period for such years.\n\nThe evidence that was before the Tax Court Judge included a reconci
- Gross Negligence
"In determining that the Minister of National Revenue (Minister) could reassess the statute-barred years and also assess gross negligence penalties, the Tax Court Judge relied mainly on the decision o