26 May 2016 IFA Roundtable Q. 11, 2016-0642031C6 - PLOI late-filed penalties -- summary under Subsection 212.3(13)

Where a corporation resident in Canada wishes to make PLOI elections respecting intercompany balances resulting from hundreds of intercompany sales, CRA considers that “each intercompany transaction resulting in a receivable… should be treated as a unique amount of indebtedness,” so that the $100 per month late filing penalty must be calculated separately with respect to each such receivable. However, “the possibility of providing administrative relief in this regard is currently under review,” e.g., “aggregat[ing] certain amounts receivable… on an annual, quarterly, or monthly basis.”