Chapter

CRA restricts taxpayer requests to revise permissive deductions

From Colubriale v. Canada, 2005 FCA 329 by Un actionnaire vend un immeuble à sa société

Concepts

1. 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

2. Requested Adjustments

   "A 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 amo

3. Partnership Adjustments

   "At the partnership level, adjustments will only be considered if all members of the partnership meet the conditions set out in the Circular, and all partners' tax returns remain open to reassessment.