How far back can the CRA reassess my tax return?
There is a defined window for each year, and it is not the same for every taxpayer. It differs by taxpayer type, so the answer for an individual is not the answer for the company they own. The window can also be extended in defined circumstances, and that second point is the one that catches people: a year looking closed on the ordinary window may not be closed at all. So the question to ask about an old year is not simply how much time has passed, but whether any of the circumstances that extend the window apply to it. Establish that before treating a year as settled.
Can the CRA reopen a year that is already closed?
The window can be extended in defined circumstances, so yes, in those circumstances. The practical approach is to treat the ordinary window as the starting point and the extending circumstances as the real question, because they are what decides whether a year is genuinely finished. That matters most on files where something in the year was unusual: a transaction with a foreign element, an amount whose treatment was a judgement call, or a position taken on information that later turned out to be incomplete. On those, check the extension question before advising anyone that the year is beyond reach.
Is the reassessment period different for a corporation?
It differs by taxpayer type, which is why the same year can be open for one party to a transaction and closed for another. On owner-managed files that is a live issue rather than a technicality. An adjustment made in a company's still-open year can have a counterpart in a shareholder's year that is no longer within reach, or the reverse. Map the windows for every party before proposing an adjustment that affects more than one of them. Doing it the other way round produces a correction on one side with no matching correction available on the other.
Does asking to amend an old return reopen the year?
The first question is whether the year is still within its reassessment period at all, because that decides what a request can achieve. Establish the window before drafting the request, not after. There is a second question people skip, which is whether you want the year looked at. A request draws attention to a year and to whatever else is in it, and on a file where other positions in the same year are less certain, that is a consideration rather than a detail. Decide what the amendment is worth against what else the year contains.
How long should I keep records after a year is assessed?
Longer than the ordinary window, because the window can be extended in defined circumstances and the extension question cannot be answered without the papers. Records are also what a later position is built on. A year closed against reassessment can still be the year in which a balance, a cost base or a carried-forward amount was established, and that figure will be relied on in an open year eventually. Keep the material supporting anything still being carried, regardless of whether the year it arose in is beyond reach.
Do both countries have the same reassessment window?
No, and that mismatch is what makes cross-border files awkward here. Each system has its own window, its own variations by taxpayer type and its own extending circumstances, so a year can be closed in one country and open in the other. The consequence is practical: an adjustment in the country where the year is still open may have no counterpart available in the country where it is not, and the relief that would normally match the two is out of reach. Where a foreign adjustment is foreseeable, map both windows for the year before it arrives rather than after. The number is +1 (416) 619-0068 and our fee is agreed in writing before work starts.
Which countries have a tax treaty with the United States?
Around sixty, including Canada, the United Kingdom, India, Australia and most of western Europe — but the list matters less than the terms, because each treaty caps rates and allocates income differently. Two countries with treaties can produce opposite answers on the same pension or the same royalty. What decides your position is the specific article covering your income type. See our country guides.
Branch or subsidiary — which should we use to expand?
A branch keeps one taxpayer: results consolidate at home, losses are usable sooner, and the exposure is that the branch is a permanent establishment whose profit the host country taxes, sometimes with a branch tax on repatriation. A subsidiary is a separate taxpayer with limited liability and local rates, at the cost of withholding on dividends home and transfer pricing on everything between them. The deciding facts are usually expected losses, liability and exit plans. See branch against subsidiary.
