ARTICLE
3 February 2016

Application Under Subsection 220(2.1) ITA Where Out Of Time For Notice Of Objection

RS
Rotfleisch & Samulovitch P.C.

Contributor

Rotfleisch Samulovitch PC is one of Canada's premier boutique tax law firms. Its website, taxpage.com, has a large database of original Canadian tax articles. Founding tax lawyer David J Rotfleisch, JD, CA, CPA, frequently appears in print, radio and television. Their tax lawyers deal with CRA auditors and collectors on a daily basis and carry out tax planning as well.
The Federal Court of Canada ruled in Conocophillips Canada Resources Corp. v MNR T-1811-12 that CRA can waive the obligation to serve an income tax notice of objection under subsection 220(2.1) of the Income Tax Act.
Canada Tax

The Federal Court of Canada ruled in Conocophillips Canada Resources Corp. v MNR T-1811-12 that CRA can waive the obligation to serve an income tax notice of objection under subsection 220(2.1) of the Income Tax Act. This means that in some circumstances even if the limitation period to file an Objection has been missed a Toronto tax litigation lawyer can apply to CRA to waive this requirement and in effect a late income tax objection can be processed.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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