Does a Minister have to identify sources of net worth as arbitrarily determined by the Minister?
Canada (Federal), Canada
The following excerpt is from Owda v. The Queen, 2019 TCC 46 (CanLII):
Jurisprudence has established that net worth assessments are imprecise approximations of a taxpayer’s income. The Minister is not obliged to identify sources of the taxpayer’s wealth approximation as arbitrarily determined by the Minister. Failure of a taxpayer to keep adequate books and records for determination of his/her/its taxable income is sufficient to justify use of the net worth method of assessment. (See Malone v. R., 2006 TCC 133, para. 3 and Hsu v. R., 2001 FCA 240, para. 30.)
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