Devon Canada Corporation v. Canada, 2015 FCA 214 -- summary under Subsection 165(1.11)

By services, 28 November, 2015

Webb JA found that where an appeals officer considers and communicates rejection of subsequently-raised issues, this has the effect of amending the Notice, so that the new issues can also be raised in a Notice of Appeal. He also stated:

[S]ince the Minister accepted these submissions, it is a moot point whether the Minister could have refused to accept them on the basis that they were made well after the time permitted…for seeking an extension of time to file a notice of objection, had expired.

See summary under s. 169(2.1).

Topics and taglines
Topic
Income Tax Act - s. 165(1.11)
Tagline
large corporations can appeal new issues which were rejected by CRA Appeals, and perhaps may raise new issues within 1 year of Objection
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
334899
Extra import data
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