CRA will process a late-filed notification under s. 116(3) as long as it is complete and received on or before the due date of the non-resident vendor's Part I return

The non-resident beneficiary of an estate does not file a Form T2062 notice respecting the disposition (occurring on a distribution) of a portion of their capital interest in an estate that is taxable Canadian property and not excluded property, and the estate does not file a notice under s.116(5.02).

CRA indicated:

• No late notification by the purchaser (considered here to be the estate) is allowed under s. 116(5.02).
• If the purchaser does not file the s. 116(5.02) notice within the required 30 days, then the non-resident vendor is required to file the s. 116(3) notice because the excluded property exemption is not available.
• Administratively, CRA will process a late-filed notification under s. 116(3) as long as it is complete and received on or before the due date of the non-resident vendor's Part I income tax return for the taxation year during which the disposition occurred. When the CRA has verified the information provided in the notice, the CRA will issue a certificate of compliance to the non-resident vendor with a copy to the purchaser. The issuance of the certificate of compliance will relieve the purchaser of their obligation even though the notification was late.

Neal Armstrong. Summary of 17 June 2025 STEP Roundtable, Q.14 under s. 116(3).