A T5013 contains a misrepresentation attributable to neglect etc. Can the Minister make a determination under s. 152(1.4) beyond the 3-year period described therein? CRA responded:
[P]ursuant to subsection 152(1.2)… as it applies with such modifications to a determination in respect of a partnership under subsection 152(1.4)…, the Minister may determine any income or loss of a partnership for a fiscal period and any deduction or other amount, or any other matter in respect of the partnership for the fiscal period beyond the three year period described therein where any of the exceptions described in subsection 152(4) of the Act apply.
Accordingly…where it is established that a partnership or person filing the partnership return made any misrepresentation that is attributable to neglect [etc.]…, a determination in respect of the partnership for a fiscal period may be made beyond the three-year period….