Will CRA apply IT-119R4 to give administrative relief from interest and penalties relating to the requirement to withhold tax on deemed dividends to non-residents arising from s. 90(6)?
Response
: CRA generally looks to its practices on s. 15(2) to deal with practical issues involving the application of proposed ss. 90(6) to 90(15). However, as proposed s. 90(6) only applies to include a "specified amount" in the income of a taxpayer resident in Canada, consistently with its practice respecting the application of subsection 15(2) to Canadian resident debtors, CRA will not provide administrative relief from interest and penalties in the context of the application of proposed s. 90(6). Instead, it will exercise its right of enforcement.