CRA New Rules For Interest Relief based On Bozzer Case (Part II)

Ten Year Limitation Period for CRA to Waive Penalties and Interest – Information Circulars IC00-1R5 Voluntary Disclosures Program and IC07-1 Taxpayer Relief Provisions Updated – A Toronto Tax Lawyer Analysis – Part II

In part I of this article, our Toronto tax law firm discussed the CRA's discretionary powers to waive or cancel all or part of the interests and penalties owed by a taxpayer. We also discussed the two programs the CRA created to facilitate the use of those powers - the Taxpayer Relief Provisions and the Voluntary Disclosures Program.

In part II of this article, we will discuss the 10 year limitation period imposed upon the CRA regarding their ability to waive interests and penalties. In addition, we will also discuss how the tax case of Bozzer v Canada has clarified how that 10 year period should be determined.