Individuals, persons and corporate persons

Individuals (people) and Corporations are referred to by CRA as Persons. So in other words, a human being is a person and a corporation is a person, but only humans are treated as individuals by CRA.

Statute Barred Years are considered closed by CRA.

If CRA issues arbitrary assessments against a corporation that has not filed it's tax returns, and the taxpayer does not object within 3 years from the date on the notice of assessment, CRA's policy is to not accept the filings. At least that is their policy on a case we are dealing with where there were business losses but CRA assessed large income and 100K in tax liability.

We can't help but wonder what their policy would be if the tax owed was higher than the arbitrary assessments.

So we are at war over this. Section 330 (3) of the income tax act says the Minister may at any time extend the time to file.

CRA is saying that issuing an assessment is a "filing" of the tax returns.

We shall see what happens in court. Somehow I don't think that CRA should be able to collect tax that should not be owed, simply on a technicality or a loophole.

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