2 December 2008 External T.I. 2008-0301761E5 F - Prepayment of Reassessments - Refund Interest -- summary under Subsection 164(3)

A corporation makes an advance payment in anticipation of a reassessment, with CRA subsequently refunding a portion of such amount pursuant to s. 164(1). After indicating that Whether the CRA generally is required to pay refund interest on such amount pursuant to s. 164(3) of the Act. However, the Directorate went on to note that the practice of accepting such an advance payment extended “only in respect of a genuine possibility of reassessment.”