9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 4, 2015-0588971C6 F - T1135 and voluntary disclosure -- summary under Subsection 162(7)

Where there has been a voluntary disclosure for failure of the taxpayer to file T1135s for the past, say, 15 years, the current practice of CRA is to assess the $2,500 per-year penalty for the first five years as being before the 10-year period for which CRA is permitted to waive penalties under s. 220(3.1). However, the proposition that “the late-filing penalty of $2,500 under subsection 162(7) applies automatically… is currently under study.”