Reliance on a section 116 certificate

In Landbouwbedrijf Backx BV v R, 2021 TCC 2, the court held that the CRA was not bound by a section 116 “letter” it had issued that had found, in effect, that the taxpayer was not a resident of Canada. The CRA was entitled to assess the taxpayer later as a resident of Canada despite the letter because it was only for “reporting and collection purposes”.

Shaira Nanjii and Byron Beswick “Landbouwbedrijf: Second TCC Decision” Canadian Tax Focus 11:2 (May 2021)

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