CRA is thinking about providing administrative relief on computing late-filed PLOI election penalties on a debit-by-debit basis

Where a corporation resident in Canada wishes to make PLOI elections respecting intercompany balances resulting from hundreds of intercompany sales, CRA considers that “each intercompany transaction resulting in a receivable… should be treated as a unique amount of indebtedness,” so that the $100 per month late filing penalty must be calculated separately with respect to each such receivable. However, “the possibility of providing administrative relief in this regard is currently under review,” e.g., “aggregat[ing] certain amounts receivable… on an annual, quarterly, or monthly basis.”

Neal Armstrong. Summaries of 26 May 2016 IFA Roundtable, Q. 11, 2016-0642031C6 under 15(2.13) and s. 212(13).