682. Loss of tax brought about carelessly or deliberately, or involving offshore matter or offshore transfer.

An assessment on a person ('the person in default') in a case involving a loss of income tax or capital gains tax brought about carelessly by the person1 may be made at any time not more than six years after the end of the year of assessment2 to which it relates3. An assessment on a person in a case involving a loss of income tax or capital gains tax: (1) brought about deliberately by the person4; (2) attributable to a failure by the person to comply with an obligation to give notice of being chargeable to income tax or