A large corporation must describe in its notice of objection each issue to be decided and must specify the relief sought for each issue in terms of a change in a balance (s. 165(1.11)). The corporation may only appeal to the Tax Court those issues specified in its notice of objection (s. 169(2.1)). In Devon Canada Corporation v. The Queen, 2015 FCA 214 (copy attached), the Federal Court of Appeal held that the “notice of objection” includes both the original notice of objection plus any additional submissions considered by the Minister at the objection stage. In this particular case, Minister in fact considered additional issues at the objection stage that were not specified in the original notice of objection. This meant that the corporation was able to appeal all the issues to the Tax Court.