Tax Court of Canada


Taxation

GOODS AND SERVICES TAX
Minister not statute-barred from assessing taxpayer more than four years after corporation filed returns

Appeal by taxpayer from assessment by Minister under Excise Tax Act (Can.). Taxpayer was director of corporation. Corporation failed to remit GST for reported period ending February 28, 1994 to May 31, 1999. Taxpayer was assessed by way of director’s liability assessment. Appeal dismissed. Minister was not statute-barred from assessing taxpayer more than four years after corporation filed its returns. Due diligence defence was not applicable. Taxpayer could not successfully argue that he was assessed more than two years after ceasing to be director.

Siow v. Canada

(June 14, 2011, T.C.C., Pizzitelli J., File No. 2008-3820(GST)G) 204 A.C.W.S. (3d) 938 (19 pp.).

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