The purpose of this newsletter is to update our clients and colleagues on the status of tax filing and payment due date extensions, particularly those that are close to ending.

Since the Covid-19 crisis began in mid-March 2020, the Canada Revenue Agency (“CRA”) has announced many tax filing and payment extensions to assist taxpayers in meeting their obligations.

On July 27, 2020, the CRA announced a further extension of the tax payment due dates for individual, corporation, and trust income tax returns to September 30, 2020. Although the filing due dates for these returns remain unchanged from the previously extended filing dates (September 1, 2020), late-filing penalties will not apply as long as both the returns and payments are made by September 30, 2020. The discrepancy between the filing and payment due dates is to encourage taxpayers to file their income tax returns as soon as possible to avoid interruptions to benefit and credit payments.

T1 Personal Income Tax and Benefit Returns – Extended Deadline

CRA has announced that penalties and interest will not be charged on 2019 T1 Personal Income Tax and Benefit Returns where the return is filed, and any balance owing is paid, by September 30, 2020.  This extension also applies to personal income tax instalments ordinarily due on June 15, 2020 and September 15, 2020.
Penalties and interest will not be applied to most 2019 information returns, elections, designations, and information requests provided that they are filed, and any associated payments due are made, by September 1, 2020. Revenue Québec has announced the same personal tax payment extension and late-filing penalty relief.
The federal extensions for individuals announced by the CRA also apply to Alberta.

T2 Corporation Income Tax Returns – Extended Deadline

Corporations that would otherwise have an income tax balance or instalment due on or after March 18 and before September 30, 2020 may now make these payments by September 30, 2020. The filing deadline for T2 returns that would otherwise be due between May 31, 2020 and August 31, 2020 has not changed from the previously extended due date of September 1, 2020. However, late-filing penalties will not be charged where a 2019 or 2020 T2 return is filed by September 30, 2020.
Revenue Québec has announced that instalments and income tax balances that would have been due between March 17 and September 29, 2020 are now due on September 30, 2020.

Alberta Tax and Revenue Administration (“TRA”) has also announced a similar extension. For corporate income tax balances owing on or after March 18, 2020, or instalment payments due between March 18, 2020 and September 30, 2020, Alberta corporations may defer making these payments until September 30, 2020.
Despite the unchanged corporate income tax filing deadlines, Revenue Québec and TRA have confirmed that a late-filing penalty will not apply as long as the return is filed by September 30, 2020.

Goods and Services Tax (“GST”) / Harmonized Sales Tax (“HST)” Extended Payment Deadline

Registrants with GST/HST remittances due on or after March 27, 2020, and before June 1, 2020, could defer those payments to June 30, 2020.  There have no announcements of further extension, so these payments should be made on or before June 30, 2020 to avoid arrears interest and potential penalties.

Objections – Extended Deadlines

Notices of objection, which are filed to dispute tax assessments or reassessments, originally due between March 18, 2020 and June 30, 2020 were extended to June 30, 2020.  No further extensions have been announced.

Collections – Deferred Action

Collection activities in respect of new debts were, and remain, suspended until further notice. CRA has announced an intention to offer flexible payment arrangements once collection activities resume. For pre-existing debts, collections staff will address each situation individually to prevent financial hardship.

Audits and Requests for Information

CRA has announced it is resuming audits and requests for information and will prioritize audits that:

  • are beneficial to the taxpayer;
  • possess a matter of urgency for the taxpayer;
  • involve higher dollar figures;
  • are close to completion;
  • have a strategic importance to the Government of Canada; or
  • combat suspected fraud and other criminal activity.

CRA also announced that requests for information issued before March 16, 2020 will be reviewed, and that taxpayers and third parties such as tax advisors will be contacted where CRA continues to require the requested information.

Other Resources

CRA has summarized current information on tax filing and payment deadlines here.
Revenue Québec has summarized current information on tax filing and payment deadlines here.
TRA has summarized current information on tax filing and payment deadlines here.
Information on GST/HST remittance due dates is located here.