I have a client - who came to me in the fall of this year.
He did not file for the years 2015/2016/2017/2018 and as such was self-assessed by the CRA on September 21 2021.
I filed these returns for him and submitted them on December 17th 2024 - they came back with a letter which basically summarized "Under subsection 152(4) of the Income Tax Act, we can reassess a corporation return for a particular tax year if we receive the request before the end of the normal reassessment period. This period begins on the date of the original notice of assessment or the notification that no tax was payable for a tax year. It ends three years from this date for a Canadian-controlled private corporation and four years from this date for all other corporations.
Because we originally assessed the returns on September 23, 2021, and we received your requests on December 12, 2024, December 16, 2024 and December 17, 2024, we cannot process your adjustment."
Has any one had a situation like this? What are some ways I can have the CRA accept these returns? I asked if I could do an objection, but because a Notice of reassessment was not issued it may not be possible. Additionally there are some limitations of objection - one of which is “T2 accounts – statute barred refund”. Basically the CRA assessed that the client has a balance owing in their self assessment but when the returns are properly filed - there is no balance owing and instead a refund from the amounts the CRA previously calculated. I also reached out to business inquiries - but they are pretty useless truth be told!
Anyone have any experience with filing a “Waiver in respect of the normal reassessment period or extended reassessment period”
Any help in this matter would be greatly appreciated.