Edwin G. (Ed) Kroft KC spoke at the Tax Executives Institute Inc. (TEI) 58th Annual Canadian Tax Conference, held May 3–6 in Ottawa.
His session examined the Canada Revenue Agency’s use of subsection 152(9) of the Income Tax Act to advance new arguments in support of reassessments, sometimes long after a tax audit has ended. Ed discussed the practical and evidentiary challenges that the use of subsection 152(9) of the Income Tax Act can create for taxpayers. He also explained some of the legal limits on the CRA’s ability to rely on subsection 152(9), including circumstances where doing so may be constrained even after limitation periods have expired.