Are you dealing with a CRA audit, appeal or collection matter? Looking to apply for interest or penalty relief? Questions about CERB eligibility and repayment? Contact Melanie at Nijhawan McMillan Petrunia Barristers today to see how we can help.
In the recent decision Hughes v. Her Majesty the Queen, 2016-465(IT)I, Justice Jorré reviewed the conditions necessary for the application of subsection 162(2), in light of the variations between the English and French versions of the Income Tax Act. The English version reads: 162(2) Every person (a) who fails to file a return of income for a taxation year as and when required by subsection 150(1), (b) to whom a demand for a return for the year has been sent und