In 994552 N.W.T. Ltd. v R, 2025 TCC 55, Mr Justice Bocock considered whether the taxpayer corporation was liable to be reassessed beyond the normal reassessment period for two taxation years and for gross negligence penalties for overclaimed capital cost allowance. The Court concluded that the CRA was entitled to reassess beyond the normal reassessment period because the taxpayer and its accountants reviewed the financial statements and T183s but not the related T2s that contained the errors in question (¶46). Gross negligence penalties, on the other hand, were not sustained: the CRA had not discharged its onus to show the “high degree of negligence” necessary to justify such penalties (¶35). See summary by B Alade and H Bourgeois Tax Topics no 2732 (June 3, 2025).
