In the course of a general discussion of waiver of penalties and interest for failure to timely file T1135s, CRA stated:
The following four factors will be considered in the CRA's analysis to determine whether or not the penalty and interest may or may not be waived:
1. the taxpayer has, in the past, fulfilled the taxpayer’s tax obligations,
2. the taxpayer knowingly left an outstanding balance that resulted in interest on arrears,
3. the taxpayer has made reasonable efforts and has not been negligent in the taxpayer’s conduct of the taxpayer’s affairs under self-assessment regime; and
4. the taxpayer has acted diligently to remedy any delay or omission.