1, as amended (the "I.T.A."), by the Tax Court of Canada (the "T.C.C.") and the Federal Court of Appeal (the "F.C.A.").
Owing to the complexity of the I.T.A., the large volume of transactions reported by large corporations on their returns, the plethora and scope of issues, and the substantial number of steps and computations involved in the proper determination of a large corporation's tax liability, it is impractical to require large corporations, with respect to each issue, to specify all the "particular elements" in their notices of objections that would then become fixed in respect of the issues, relief, and maximum amount.
Given the size and complexity of business operations and the tax issues, the I.T.A. accords the C.R.A.