A reassessment can be issued beyond the normal reassessment period if the Minister shows that the taxpayer’s return contained a misrepresentation attributable to neglect, carelessness,  or willful default (s. 152(4)(a)(i)).  In Robertson v. The Queen, 2015 TCC 246 (copy attached), a Canadian resident director did not report (in his Canadian tax return) stock options exercised by him in connection with a US company.  The failure to report was described as “an honest mistake of law”: i.e., the director honestly believed the options were taxable only in the US.  However, the mistake – a misrepresentation – was “attributable to neglect” because it did not reflect some arguable question of interpretation.  Rather the law (s. 7) is crystal clear: the options were taxable in Canada.  Ignorantia non excusat lex; ignorance of the law excuses no one (see paragraph 27).  Furthermore, “a wise and prudent person” must either know the law or retain someone who does.  The taxpayer should have at least raised the possibility that his stock options might be taxable in Canada, at the time his accountant was preparing the return (see paragraph 34).