1006.1. Where at any time, by reason of section 1079.10, the Minister ascertains the tax consequences to a taxpayer with respect to a transaction, the Minister shall, in the case of a determination pursuant to section 1079.16, or the Minister may, in any other case, determine any amount that is, or could at a subsequent time be, relevant for the purposes of computing the income, taxable income or taxable income earned in Canada of, tax or other amount payable by, or amount refundable to, the taxpayer. Where such a determination is made, the Minister shall send, with all due dispatch, a notice of determination to the taxpayer.
The determination is binding on both the Minister and the taxpayer for the purposes of computing the income, taxable income or taxable income earned in Canada of, tax or other amount payable by, or amount refundable to, the taxpayer for any taxation year, subject to the taxpayer’s rights of objection, contestation and appeal in respect of the determination or subject to any redetermination by the Minister.
Despite the first paragraph, no determination may be made by the Minister in a taxation year solely for the purposes of computing the income, taxable income or taxable income earned in Canada of, tax or other amount payable by, or amount refundable to, the taxpayer for a preceding taxation year.
1990, c. 59, s. 339; 2020, c. 122020, c. 12, s. 14612; 2023, c. 192023, c. 19, s. 101111.