Banque de Nouvelle-Écosse c. Canada — 2024 CAF 192

The Federal Court of Appeal upheld interest charges of nearly $8 million against the Bank of Nova Scotia under s. 161(7)(b)(iv) of the Income Tax Act, holding that the carve-out period for a loss carry-back runs until the written request triggering the reassessment, not merely until the loss-year return was filed. The decision clarifies how arrears interest is calculated when an audit adjustment and a corresponding loss carry-back are assessed simultaneously.