In correspondence released October 10, 2012 (2012-0455781E5), the CRA said it has the power to reassess a dissolved Ontario company. This stems from s. 242(1)(b) of the Business Corporations Act (Ontario), which provides that a civil, criminal, or administrative action or proceeding may be brought against a corporation after its dissolution, as if the corporation had not been dissolved. Further, in Dominion of Canada General Insurance Co. v. The Queen,  C.T.C. 190, the Federal Court Trial Division confirmed that the issuance of a notice of assessment is an “administrative action or proceeding”. Any assessment of a dissolved company might then form the basis of a derivative assessing action under s. 159 or s. 160 of the Income Tax Act (Canada) (ITA). The CRA statements were made in connection with a third party’s request for tax information relating to the dissolved company (a lender seeking information in support of a title insurance application). The CRA also confirmed that it could not release to the third party any tax information relating to the dissolved company, as a result of the confidentiality provisions of the ITA (s. 241).