Introduction – The Canada Revenue Agency's Power to
Reassess
Prince v MNR (2020 FCA 32) illustrates that the Canada Revenue
Agency's tax-reassessment powers come with few limits. The
Federal Court of Appeal held that the Canada Revenue Agency could
validly reassess a taxpayer even though the taxpayer's
unresolved voluntary-disclosure application might bear on the
correctness of those reassessments.
Above all, the Prince case reveals the broad tax-assessing
powers of CRA and why you should retain an experienced Canadian tax
lawyer early in the CRA tax-dispute process. Without the aid of an
experienced Canadian tax lawyer, you might find yourself seeking
relief in an inappropriate forum. The Prince taxpayer, for
instance, sought judicial review under the Federal Courts Act when
he probably should have pursued the issue solely under the
tax-dispute process in the Income Tax Act.
