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On September 1 , 2 0 2 3 , you started in your new position as manager of taxation for XYZ Corporation, a large public

On September 1,2023, you started in your new position as manager of taxation for XYZ Corporation, a large public company with a December 31 year end. On the second day into the job, Samael Bazyli, the VP Finance, shares with you a folder saved in the company's networked drive entitled "Outstanding Tax Items". He tells you that the IT department
was cleaning up the previous tax manager's files and found this folder which contains copies of reassessments and statements. He is concerned about the following items found in the file:
ITA: 161,162,163.1; IC 00-IR
(a) The corporation's Notice of Assessment for the 2017 taxation year (dated September 30,2018) as well as a reassessment, dated April 30,2023. The reassessment indicates that the corporation has been assessed additional tax for the 2017 taxation year in the amount of $722,500.
(b) An instalment statement indicating that for the 2022 taxation year minimum instalments were made for January to October, no instalment was made in November, and an instalment of $1.45 million was made in December.
(c) A draft T2 corporate tax return for the company for the 2022 taxation year indicating taxes payable of $12.76 million. Samael indicated that he doesn't think that the return was filed.
(d) An excel file summarizing information from previous tax returns showing the tax liabilities for the 2019 to 2021 taxation years of $7.5 million, $6.6 million, and $9.2 million, respectively.
Mr. Bazyli has asked you to review the information and provide him with the following:
(A) Comment on the validity of the CRA reassessment.
(B) Determine whether there is tax owing for the 2022 taxation year, calculate any late filing penalties, if any, and comment on any late instalment penalties, if any.
(C) Discuss the interest charges applicable, assuming a prescribed rate of 4%.

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