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Appeal regarding the deemed payment date for calculating arrears interest on a loss carryback dismissed.
The appellant appealed a reassessment for its 2006 taxation year concerning the calculation of arrears interest.
Following a transfer pricing audit and settlement, the appellant requested a carryback of a 2008 non-capital loss to offset the resulting increase in 2006 income.
The Minister calculated interest based on the date of the written request, while the appellant argued it should be based on the filing date of the loss year return.
The Tax Court of Canada dismissed the appeal, finding that the unambiguous wording of the Income Tax Act required the deemed payment date to be based on the date of the written request.
