What is meant by reasonable error in s. 204.1(4) and s. 207.06(1), and when will CRA exercise its discretion thereunder? CRA responded:
[R]easonable error means in the first instance that the excess is genuinely the result of an error and that the taxpayer did not intentionally overcontribute. For the error to be reasonable, it must also be considered by an impartial person to be more likely to occur rather than less likely to occur based on the circumstances of the taxpayer. …