An employee (tax manager) of Amdocs Inc did not cooperate with the Canada Revenue Agency during several audits of the company and did not inform his superior about the audits. The audits resulted in tax reassessments for FY 2012 – 2014.
The reassessment concerning FY 2012 resulted in income tax payable by $3,353,906, but by the time the employee informed his superior of the reassessment in 2019, Amdocs was time barred from objecting by virtue of the limitation periods. With respect to the assessments for FY 2013 and 2014 the limitation period for objections had not yet elapsed.
Amdocs Inc filed an appeal with the court in regards of the denied access to object on the assessment for FY 2012.
Judgement of the Federal Court
The court dismissed the appeal of Amdocs and decided in favor of the tax authorities.
“…I find the Minister’s decision is reasonable. The Minister’s decision is internally coherent and justified in relation to the relevant facts and law, and the Applicant has not identified any flaws in the Minister’s decision that are sufficiently central or significant. I therefore dismiss this application for judicial review.”
Canada vs Amdocs CMS 2021_FC_707