Are there any cases where a Minister was permitted to make a tax assessment after the expiry of the normal reassessment period?
Canada (Federal), Canada
The following excerpt is from Canada v. Anchor Pointe Energy Ltd., 2003 FCA 294 (CanLII):
In my opinion, he was not. This case is unlike cases such as Pedwell v. The Queen, 2000 D.T.C. 6050 (F.C.A.), where the Minister sought to take into account different transactions than the ones that formed the basis of the reassessments that were made within the normal reassessment period. I do not say that taking into account other transactions is the only thing the Minister cannot do after expiry of the normal reassessment period. Anything that increases tax payable from what would have been the case prior to expiry of the normal reassessment period would be objectionable.
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