Canada v. Loewen (F.C.A.), 2004 FCA 146, [2004] 4 FCR 3
Canada v. Loewen (F.C.A.), 2004 FCA 146, 4 FCR 3
Can the Canada Revenue Agency (“CRA”), after the expiry of the reassessment period, defend an assessment by relying on a new legal argument or additional facts that were not part of the CRA’s original assumptions, without effectively making a new...