In Milgram Foundation v. Canada (Attorney General), 2024 FC 1405, the Federal Court quashed a decision to reassess a taxpayer for taxation years before years for which the taxpayer had made a voluntary disclosure. The CRA had accepted the disclosure as voluntary and complete, but then proceeded to reassess the taxpayer for some years before the VD period. The Federal Court quashed the decision to reassess on the basis that it was an abuse of process. The Crown has appealed this decision.
