CRA stated that it:
accepts advance payments made by corporations in anticipation of a reassessment under the Act.
This allows the corporation to reduce its arrears interest expense pursuant to subsection 161(1). Under this provision, such interest charges accrue from the corporation's "balance-due date" (as defined in subsection 248(1)) for the particular taxation year, regardless of the date on which the Minister reassesses. …
[T[he CRA's position is also to accept advance payments made by individuals in anticipation of a reassessment under the Act. …
[U]nder subsection 152(3), the fact that no assessment has been made does not affect the taxpayer's liability for Part I tax.