In Remtilla v. The Queen (2015 TCC 200) V.A. Miller J determined that T1 adjustment request filed by a taxpayer’s representative constituted valid waivers of the normal reassessment period. The court found that a valid waiver must include all the prescribed information, and also must have been intended by the taxpayer to function as a waiver. The second point should be determined from the perspective of an objective reasonable bystander. The court found based on the conduct of the representative that an objective reasonable observer would conclude that the T1 adjustment requests were intended to function as waivers, and so permitted the Minister to assess beyond the normal reassessment period.