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ARTICLE · 29 JUNE 2020

Income Tax Reassessment Periods – Proposed Changes

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Subsection 152(1) of the Income Tax Act (the "Act") imposes that the Canada Revenue Agency ("CRA") "with all due dispatch", examine and assess an income tax return of a taxpayer.

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Aasim Hirji
Aasim Hirji
Christopher Ellett
Christopher Ellett
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Subsection 152(1) of the Income Tax Act (the "Act") imposes that the Canada Revenue Agency ("CRA") "with all due dispatch", examine and assess an income tax return of a taxpayer. This usually results in the CRA issuing a quick Notice of Assessment and relying on the "normal reassessment period" to further examine a tax return.

Subsection 152(3.1) of the Act provides that the "normal reassessment period" for a taxpayer is:

  • If the corporation is a Canadian-controlled private corporation ("CCPC"), an individual, or a trust (that is not a mutual fund trust) within three years of the date the original notice of assessment was sent or the sent date of the original notification that no tax is payable (whichever is earlier); and

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