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ARTICLE · 28 OCTOBER 2020

CRA Operational Update - Ten Things You Need To Know

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On October 21, three senior Canada Revenue Agency ('CRA') officials outlined a status update on tax controversy and dispute resolution at this stage of the COVID-19 pandemic.

CanadaTax
Stevan Novoselac
Stevan Novoselac
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On October 21, three senior Canada Revenue Agency ('CRA') officials outlined a status update on tax controversy and dispute resolution at this stage of the COVID-19 pandemic. As the presentation was not recorded, we summarized the top ten topics covered.1

1. TheTime Limits and Other Periods Act (COVID-19) ('TLOPA')

  • The TLOPA applies to allow the suspension or extension of time limits for taking certain steps under numerous statutes,2 including the Income Tax Act and the Excise Tax Act. However, the TLOPA does not affect treaty-based statute-barred dates. Further, the TLOPA suspensions/extensions expire after December 31, 2020.
  • In the small and medium-sized enterprise space, the decision whether to rely on the TLOPA to reassess a year that would otherwise have become statute-barred will be made on a case-by-case basis, taking into account the taxpayer's particular circumstances, including collectability issues.

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