April 24, 2012
As you may be aware, the Court-appointed Representatives, through their legal counsel Koskie Minsky LLP, will be testing the correctness in law of certain Advance Income Tax Rulings adverse to taxpayers that were issued by the CRA in July 2011 to the effect that lump sum payments made in connection with the termination of group term life insurance coverage and in connection with termination of survivor income benefits are to be included in income subject to tax (the “Tax Court References”).
After you file your income tax returns, CRA will send you an assessment. Individuals who wish to preserve their entitlement to have their 2011 taxation year reassessed in the event of a favourable outcome on one or both of the Tax Court References must file a Notice of Objection in a timely manner to the assessment received from CRA in respect of the 2011 year (and 2012 year return when applicable). Those individuals resident in Québec must also file a Notice of Objection in a timely manner to the assessment received from Revenu Québec in respect of the same year or years.
Koskie Minsky is in the process of preparing a package of information elaborating upon the manner in which the affected individuals can preserve their rights to be reassessed in the event of a favourable outcome on the Tax Court References. Please be patient. You will receive this package in the coming weeks.
Important Note: Only object to your 2011 assessment if you received a T4A for these benefits that is dated 2011. If you did not receive a 2011 T4A, you do not have to object at this time.