Hall v R, 2016 TCC 221, addresses the normal reassessment period for tax payable under a Part of the Income Tax Act (Canada). The case confirms that the period does not begin until an initial assessment is issued under that Part. If a taxpayer is assessed for Part I tax but not Part X.1 tax for a year, the normal reassessment period begins only for Part I tax at the time of the assessment. The period does not begin for Part X.1 assessments (the tax on RRSP over-contributions), which means that the CRA can assess Part X.1 tax at any time.
