Poor Mr Lam trusted his tenant to forward important mail while Mr Lam was out of the country, but the tenant left a 2016 HST assessment in a pile of junk mail. Mr Lam didn’t become aware of the assessment until March, 2024. He immediately filed a notice of objection, but of course he was well past the relevant limitation periods, which are set out in sections 301, 303 and 304 of the Excise Tax Act. These provisions are materially identical to those in the Income Tax Act (Canada).
Unsurprisingly, the Court, per Mr Justice Bocock, dismissed Mr Lam’s application to extend the time for filing an objection. See Lam v R, 2025 TCC 15.
