It may be negligent to advise the payment of assessed taxes to cut off interest

A non-resident corporation, which was assessed following many years of not filing T2 returns, was advised to pay the assessments, and then "successfully" objected to the assessments by establishing that its income was Treaty-exempt.

CRA now has informed the advisers that it is precluded by s. 164(1) from refunding this overpayment of tax because the corporation did not file its T2 returns for the years in question within three years from the ends of those years, i.e., by paying taxes which were not owing as a substantive matter, the corporation supposedly has lost the ability to get that money back!

Neal Armstrong.  Summary of 5 November 2014 T.I. 2014-0538901E5 under s. 164(1).