Case information
Consult our database for details on a Supreme Court of Canada case.
39553
6075240 Canada Inc. v. Minister of National Revenue
(Federal) (Civil) (By Leave)
Docket
Judgments on applications for leave to appeal are rendered by the Court, but are not necessarily unanimous.
| Date | Proceeding | Filed By (if applicable) |
|---|---|---|
| 2021-06-22 | Close file on Leave | |
| 2021-06-17 | Copy of formal judgment sent to Registrar of the Court of Appeal and all parties | |
| 2021-06-17 | Judgment on leave sent to the parties | |
| 2021-06-17 |
Judgment of the Court on the application for leave to appeal, The motion for an extension of time to serve and file the application for leave to appeal is granted. The application for leave to appeal from the judgment of the Federal Court of Appeal, Number A-208-19, 2020 CAF 194, dated November 9, 2020, is dismissed with costs. Dismissed, with costs |
|
| 2021-06-17 |
Decision on motion to extend time to file and /or serve the leave application, See decision on application Granted |
|
| 2021-05-17 | All materials on application for leave submitted to the Judges, for consideration by the Court | |
| 2021-05-17 | Submission of motion to extend time to file and/ or serve the leave application, for consideration by the Court | |
| 2021-04-01 | Response to the motion to extend the time to file and / or serve the leave application, (Letter Form), Completed on: 2021-05-17 | Minister of National Revenue |
| 2021-03-25 | Motion to extend the time to file and or serve the application for leave to appeal, (Book Form), Require: Filling fee - rec'd 2021-06-14, Completed on: 2021-05-18, (Printed version due on 2021-04-01) | 6075240 Canada Inc. |
| 2021-03-25 | Notice of name, Amended notice of name (rec'd 2021-06-04) | 6075240 Canada Inc. |
| 2021-03-23 | Certificate (on limitations to public access) | Minister of National Revenue |
| 2021-03-23 | Respondent's response on the application for leave to appeal, (Letter Form), Completed on: 2021-05-17, (Printed version due on 2021-03-30) | Minister of National Revenue |
| 2021-02-24 | Letter acknowledging receipt of an incomplete application for leave to appeal, File opened 2021-02-24 | |
| 2021-02-02 | Certificate (on limitations to public access), Amended form required | 6075240 Canada Inc. |
| 2021-01-20 |
Application for leave to appeal, (Book Form), Required: - Motion for extension of time (rec'd 2021-03-25); - Form 14 (rec'd 2021-03-25); Still missing; - Filing fee for application - rec'd 2021-06-14, Completed on: 2021-05-18 |
6075240 Canada Inc. |
Parties
Please note that in the case of closed files, the “Status” column reflects the status of the parties at the time of the proceedings. For more information about the proceedings and about the dates when the file was open, please consult the docket of the case in question.
Main parties
| Name | Role | Status |
|---|---|---|
| 6075240 Canada Inc. | Applicant | Active |
v.
| Name | Role | Status |
|---|---|---|
| Minister of National Revenue | Respondent | Active |
Counsel
Party: 6075240 Canada Inc.
Counsel
Jacques Saint-Laurent
Gatineau, Quebec
J8X 2J4
Telephone: (819) 778-7864
FAX: (819) 770-0712
Email: cdonaldson@ldlegal.ca
Party: Minister of National Revenue
Counsel
Dominik Longchamps
99, Bank Street
Ottawa, Ontario
K1A 0H8
Telephone: (613) 670-8252
FAX: (613) 941-2293
Email: charles.camirand@justice.gc.ca
Agent
50 O'Connor Street
Suite 500
Ottawa, Ontario
K1A 0H8
Telephone: (613) 670-6290
FAX: (613) 954-1920
Email: christopher.rupar@justice.gc.ca
Summary
Keywords
Taxation — Income tax — Assessment — Moment at which Act deprives taxpayer of right to have income reported for first time examined and to have tax assessed on that income for year in question — Whether taxpayer’s first income tax return can be regarded as adjustment request — Whether Federal Court of Appeal erred in law in finding that Minister of National Revenue’s decision was reasonable.
Summary
Case summaries are prepared by the Office of the Registrar of the Supreme Court of Canada (Law Branch). Please note that summaries are not provided to the Judges of the Court. They are placed on the Court file and website for information purposes only.
6075240 Canada Inc. (607) is a taxpayer that failed to file an income tax return for the 2010 and 2012 taxation years. The Minister of National Revenue therefore made an estimated assessment for those years. More than three years later, 607 tried to file income tax returns for the years in question. The Minister refused to process the returns on the basis that he could not make a reassessment after the “normal reassessment period” defined in the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.). 607 filed an application for judicial review with the Federal Court, which dismissed the application. The appeal from that decision was also dismissed.
Lower court rulings
Federal Court
T-387-16; 2019 CF 642
Application for judicial review dismissed
Federal Court of Appeal
A-208-19, 2020 CAF 194
Appeal dismissed
Filed documents
The memorandums of argument on an application for leave to appeal will be posted here 30 days after leave to appeal has been granted unless they contain personal information, information that is subject to a publication ban, or any other information that is not part of the public record. You may also obtain copies of the memorandum by filling out the Request for Court records form or by contacting the Court’s Records Centre either by email at records-dossiers@scc-csc.ca or by telephone at 613-996-8666 or at 1-844-365-9662.
If you have questions about a memorandum of argument or want to use a memorandum of argument, please contact the author of the memorandum of argument directly. Their name appears at the end of the memorandum of argument. The contact information for counsel is found in the “Counsel” tab of this page.
Downloadable PDFs
Not available
Related links
The factums of the appellant, the respondent and the intervener will be posted here at least 2 weeks before the hearing unless they contain personal information, information that is subject to a publication ban, or any other information that is not part of the public record. You may also obtain copies of factums by filling out the Request for Court records form or by contacting the Court’s Records Centre either by email at records-dossiers@scc-csc.ca or by telephone at 613-996-8666 or at 1-844-365-9662.
If you have questions about a factum or want permission to use a factum, please contact the author of the factum directly. Their contact information appears on the first page of each factum.
Downloadable PDFs
Not available
Related links
The condensed books of the appellant, the respondent and the intervener will be posted here upon receipt of the electronic version, 2 days prior to the scheduled appeal hearing. You may also obtain copies of condensed books by filling out the Request for Court records form or by contacting the Court’s Records Centre either by email at records-dossiers@scc-csc.ca or by telephone at 613-996-8666 or at 1-844-365-9662.
If you have questions about a condensed book or want permission to use a condensed book, please contact the author of the condensed book directly. Their contact information appears on the first page of each condensed book.
Downloadable PDFs
Not available