CRA New Rules For Interest Relief Based On Bozzer Case (Part I)

Ten Year Limitation Period for CRA to Waive Penalties and Interest – Clarifications from Bozzer v. Canada (2011 FCA 186) – A Toronto Tax Lawyer Analysis – Part I

CRA Discretion to Waive or Cancel Penalties and Interest

Under the Canadian Income Tax Act the Canada Revenue Agency (the "CRA") is obligated to collect any and all legitimate taxes, penalties, and interest owing from Canadian taxpayers. Generally the CRA cannot negotiate on those amounts, meaning that it cannot reduce taxes owing. This can seem harsh and unforgiving, particularly in situations where the taxpayer may not have completely been at fault. However there is an exception to this obligation in subsection 220(3.1) of the Tax Act which gives the CRA discretion to waive or cancel all or part of any interest and penalties that have accrued on a tax debt. This means that, while the CRA cannot negotiate on the base amounts of tax debt a taxpayer owes to them, they can use their discretion to waive or