Regarding the application pursuant to s. 152(1.2) of the limitation periods in s. 152(4), the Directorate indicated:
[U]sing a modified version of subsection 152(3.1), the “normal redetermination period” (within which a redetermination may be issued under subsection 152(3.4) with respect to a qualifying period) would end three (or four) years after the earlier of the date of sending the original notice under subsection 152(3.4) stating the amount deemed to be an overpayment on account of the taxpayer’s Part I tax liability that arose during the qualifying period, or stating that no such overpayment exists.
It should be noted that where no original subsection 152(3.4) notice has been sent, it is our view that the “normal redetermination period” for the relevant qualifying period would not have begun.
A redetermination beyond this time could be made based on a misrepresentation attributable to neglect etc.