CRA will not assess a s. 162(7) penalty for failure to file a nil T2 return

CRA considers that the reasoning in Exida.com indicates that a Canadian corporation with no taxable income (or a loss) for a year is subject to a s. 162(7) penalty for failure to file a nil T2 return. However, it affirmed its policy that it nonetheless will not assess the penalty in these circumstances.

Neal Armstrong. Summary of 6 October 2017 APFF Roundtable, Q.1 under s. 162(7).