In Boles v R, 2024 TCC 167, the taxpayers incurred losses in respect of “Dog Activities” (breeding and selling purebred dogs and attending dog shows) and some rental properties. The Court concluded the CRA could not reassess statute-barred years for the Dog Activities except in respect of expenses that were “obviously” personal. The CRA was entitled to reassess open years in respect of the Dog Activities because they did not constitute a source of income. The losses from the rental properties did constitute a source of income.
See summary in Tax Topics no 2724 (February 11, 2025)
