4053893 Canada Inc. v. Canada (National Revenue), 2021 FC 218

JurisdictionFederal Jurisdiction (Canada)
CourtFederal Court (Canada)
Citation2021 FC 218
Date11 March 2021
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5 practice notes
  • Ali v. Canada (Citizenship and Immigration),
    • Canada
    • Federal Court (Canada)
    • July 12, 2021
    ...(Citizenship and Immigration), 2016 FC 1054 at paras 30–32; see also, by analogy, 4053893 Canada Inc v Canada (National Revenue), 2021 FC 218 at paras 27–32. This does not mean, though, that the IAD can treat a finding by an immigration officer as determinative of an issue bef......
  • Voluntary Disclosure Applications: Canadian Tax Lawyer's Guide
    • Canada
    • Mondaq Canada
    • August 20, 2021
    ...was truly voluntary. On March 11, 2021, the Federal Court released its decision in 4053893 Canada Inc. v Canada (National Revenue), 2021 FC 218 ("4053893 Canada Inc."), concerning an application for judicial review of a CRA denial of relief under a voluntary-disclosure application. As a con......
  • Voluntary Disclosure Applications: Canadian Tax Lawyer's Guide
    • Canada
    • Mondaq Canada
    • August 20, 2021
    ...was truly voluntary. On March 11, 2021, the Federal Court released its decision in 4053893 Canada Inc. v Canada (National Revenue), 2021 FC 218 ("4053893 Canada Inc."), concerning an application for judicial review of a CRA denial of relief under a voluntary-disclosure application. As a con......
  • Voluntariness Of A Voluntary-Disclosure Application 4053893 Canada Inc ' A Canadian Tax Lawyer's Guide
    • Canada
    • Mondaq Canada
    • March 11, 2022
    ...disclosure was voluntary. On March 11, 2021, the Federal Court released a decision, 4053893 Canada Inc v Canada (National Revenue), 2021 FC 218, where the central issue involved was whether the CRA's decision to deny a corporate taxpayer's application for involuntariness was reasonable give......
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1 cases
  • Ali v. Canada (Citizenship and Immigration),
    • Canada
    • Federal Court (Canada)
    • July 12, 2021
    ...(Citizenship and Immigration), 2016 FC 1054 at paras 30–32; see also, by analogy, 4053893 Canada Inc v Canada (National Revenue), 2021 FC 218 at paras 27–32. This does not mean, though, that the IAD can treat a finding by an immigration officer as determinative of an issue bef......
4 firm's commentaries
  • Voluntary Disclosure Applications: Canadian Tax Lawyer's Guide
    • Canada
    • Mondaq Canada
    • August 20, 2021
    ...was truly voluntary. On March 11, 2021, the Federal Court released its decision in 4053893 Canada Inc. v Canada (National Revenue), 2021 FC 218 ("4053893 Canada Inc."), concerning an application for judicial review of a CRA denial of relief under a voluntary-disclosure application. As a con......
  • Voluntary Disclosure Applications: Canadian Tax Lawyer's Guide
    • Canada
    • Mondaq Canada
    • August 20, 2021
    ...was truly voluntary. On March 11, 2021, the Federal Court released its decision in 4053893 Canada Inc. v Canada (National Revenue), 2021 FC 218 ("4053893 Canada Inc."), concerning an application for judicial review of a CRA denial of relief under a voluntary-disclosure application. As a con......
  • Voluntariness Of A Voluntary-Disclosure Application 4053893 Canada Inc ' A Canadian Tax Lawyer's Guide
    • Canada
    • Mondaq Canada
    • March 11, 2022
    ...disclosure was voluntary. On March 11, 2021, the Federal Court released a decision, 4053893 Canada Inc v Canada (National Revenue), 2021 FC 218, where the central issue involved was whether the CRA's decision to deny a corporate taxpayer's application for involuntariness was reasonable give......
  • Voluntariness Of A Voluntary-Disclosure Application 4053893 Canada Inc ' A Canadian Tax Lawyer's Guide
    • Canada
    • Mondaq Canada
    • March 11, 2022
    ...disclosure was voluntary. On March 11, 2021, the Federal Court released a decision, 4053893 Canada Inc v Canada (National Revenue), 2021 FC 218, where the central issue involved was whether the CRA's decision to deny a corporate taxpayer's application for involuntariness was reasonable give......

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