Bifalgorithm post · 606036 2. Transfert d'immeubles d'une société à un actionnaire · Greer – Tax Court of Canada finds a shareholder benefit regarding a transfer to an individual shown on the register as holding one of the 1000 shares

Reassessment Period

Reassessment Period (606036 2. Transfert d'immeubles d'une société à un actionnaire · Greer – Tax Court of Canada finds a shareholder benefit regarding a trans…

Ideas in this flowchart

  • The reassessment of the taxpayer’s 2005 taxation year was not statute-barred.
  • The Minister initially assessed the wrong taxation year, 2006.
  • The Minister later reassessed the taxpayer’s correct taxation year, 2005.
  • The reassessment occurred beyond the normal reassessment period.
  • Spiro J held that the reassessment was not statute-barred under s. 152(4)(a)(i).
  • The taxpayer failed to consult a tax professional before filing the 2005 return.
  • This failure reflected a lack of reasonable care.
  • The lack of reasonable care constituted negligence.
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Reassessment Period

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606036 2. Transfert d'immeubles d'une société à un actionnaire

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"The Minister had initially assessed the wrong taxation year of the taxpayer (2006), but later reassessed his 2005 taxation year, the correct year, beyond the normal reassessment period. Spiro J found that this reassessment was not statute-barred under s. 152(4)(a)(i), stating that “[h]is failure to consult a tax professional before filing his 2005 return reflects a lack of reasonable care and was, therefore, negligent.”"

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