The appellant, a builder of residential rental properties, failed to self-assess and remit GST/HST on a multi-unit residential complex completed in 2011.
The Minister reassessed the appellant beyond the normal four-year limitation period, alleging misrepresentation attributable to neglect, carelessness, or wilful default.
The appellant argued it relied entirely on its accountant to handle its tax obligations.
The Tax Court of Canada dismissed the appeal, finding that the appellant's complete lack of engagement and failure to exercise reasonable care in understanding its tax obligations met the threshold for neglect, justifying the assessment beyond the limitation period.
