CRA confirms that it may relieve interest on deficient or insufficient pre-death instalments

CRA, after indicating that if Instalments due before the date of death of the deceased were late or insufficient, interest and possibly a penalty may apply until the date of death, stated that it may consider interest and penalty relief under s. 220(3.1) where it was demonstrated that the deceased taxpayer was unable to comply due to circumstances beyond their control. It further stated:

Each request is examined individually and the CRA takes into account various factors such as the time of death, the method used to calculate the instalments, as well as the supporting documents provided. Depending on the facts of each situation, relief may be provided for all or part of the instalments.

Neal Armstrong. Summary of 9 October 2025 APFF Roundtable, Q.4 under s. 220(3.1).