Income Tax Act — I-3.3 152
Extended period of assessment (4.01) Notwithstanding subsections (4) and (5), an assessment, reassessment or additional assessment to which any of paragraphs (4)(a) to (b.1) or (b.3) to (c) applies in respect of a taxpayer for a taxation year may be made after the taxpayer’s normal reassessment period in respect of the year to the extent that, but only to the extent that, it can reasonably be regarded as relating to, (a) where paragraph 152(4)(a) applies to the assessment, reassessment or additional assessment, (i) any misrepresentation made by the taxpayer or a person who filed the taxpayer’s return of income for the year that is attributable to neglect, carelessness or wilful default or any fraud committed by the taxpayer or that person in filing the return or supplying any information under this Act, or (ii) a matter specified in a waiver filed with the Minister in respect of the year; (b) if any of paragraphs (4)(b), (b.1) or (b.5) to (c) applies to the assessment, reassessment or additional assessment, (i) the assessment, reassessment or additional assessment to which subparagraph 152(4)(b)(i) applies, (ii) the assessment or reassessment referred to in subparagraph 152(4)(b)(ii), (iii) the transaction, income, loss or other amount referred to in subparagraph (4)(b)(iii), (iv) the payment or reimbursement referred to in subparagraph 152(4)(b)(iv), (v) the reduction referred to in subparagraph 152(4)(b)(v), (vi) the application referred to in subparagraph 152(4)(b)(vi), (vii) the deduction or claim referred to in paragraph (4)(b.1), (viii) the reportable transaction referred to in paragraph (4)(b.5), (ix) the notifiable transaction referred to in paragraph (4)(b.6), (x) any transaction, or series of transactions, to which the reportable uncertain tax treatment referred to in paragraph (4)(b.7) relates, (x.1) [Repealed, 2024, c. 17, s. 80] (x.2) [Repealed, 2024, c. 17, s. 80] (xi) the transaction referred to in subparagraph (4)(b)(viii), (xii) the transactions or events referred to in paragraph (4)(b.91), (xiii) the amounts, transactions or events referred to in paragraph (4)(b.92), (xiv) the transactions or events referred to in paragraph (4)(b.93), or (xv) the transactions or events referred to in paragraph (4)(b.95); (c) if paragraph (4)(b.3) applies to the assessment, reassessment or additional assessment, the disposition referred to in that paragraph; and (d) if paragraph (4)(b.4) applies to the assessment, reassessment or additional assessment, the reduction under subparagraph (4)(b.4)(iii). If waiver revoked (4.1) If the Minister would, but for this subsection, be entitled to reassess, make an additional assessment or assess tax, interest or penalties by virtue only of the filing of a waiver under subparagraph (4)(a)(ii) or paragraph (4)(c) or (c.1), the Minister may not make such a reassessment, additional assessment or assessment after the day that is six months after the date on which a notice of revocation of the waiver in prescribed form is filed. Reassessment with taxpayer’s consent (4.2) Notwithstanding subsections (4), (4.1) and (5), for the purpose of determining — at any time after the end of the normal reassessment period, of a taxpayer who is an individual (other than a trust) or a graduated rate estate, in respect of a taxation year — the amount of any refund to which the taxpayer is entitled at that time for the year, or a reduction of an amount payable under this Part by the taxpayer for the year, the Minister may, if the taxpayer makes an application for that determination on or before the day that is 10 calendar years after the end of that taxation year, (a) reassess tax, interest or penalties payable under this Part by the taxpayer in respect of that year; and (b) redetermine the amount, if any, deemed by any of subsections 120(2) or (2.2), 122.5(3) to (3.005), 122.51(2), 122.7(2) or (3), 122.8(4), 122.9(2), 122.91(1), 122.92(3), 122.93(2), 127.1(1), 127.41(3) or 210.2(3) or (4) to be paid on account