Recent Posts

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  DaSilva v. R. – TCC: Tax Court accepts the taxpayer’s evidence that a notice of assessment was not provided to her until August 22, 2016, not sent on January 11, 2013 as alleged by Minister

  May 30, 2018 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Commodity Tax
  • Federal Income Tax

  Précis: The taxpayer appealed to the Tax Court in respect of a denial of a claim for a GST/HST new housing rebate. The Minister moved to quash the appeal on the basis that the taxpayer’s notice of objection was not filed on a timely basis. The Minister alleged that the notice of assessment was mailed on January 11, 2013. The taxpayer alleged that she did not receive the notice of assessment until it was provided to her on August 22, 2016. The Court accepted the taxpayer’s evidence and allowed the appeal (the Minister conceded that the appeal should be allowed if the appeal was not quashed for late filing).
  DaSilva v. R. – TCC: Tax Court accepts the taxpayer’s evidence that a notice of assessment was not provided to her until August 22, 2016, not sent on January 11, 2013 as alleged by MinisterREAD MORE »
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  Mpamugo v. R. - TCC: Fraudster’s claim that he never received reassessments for $6.8M rejected

  Oct 06, 2016 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  Précis: Mr. Mpamugo was convicted and imprisoned for several years for running a fraudulent scheme to permit non-students to obtain student loans. CRA reassessed him in connection with the scheme for $6.8 million over the period from 1998 to 1999. He filed appeals with the Tax Court. CRA moved to dismiss the appeals on the basis that no notices of objection had ever been filed. Mr. Mpamugo moved to quash his own appeals on the basis that he had never received the notices of reassessment.
  Mpamugo v. R. - TCC: Fraudster’s claim that he never received reassessments for $6.8M rejectedREAD MORE »