CRA recognizes due diligence defence to paper-filing penalty
S. 162(7.3) imposes a per-return penalty for tax preparers who do not file electronically. CRA recognizes that a due diligence defence is available. For example, respecting the potentially-conflicting requirement that the return not be filed electronically without a signed T183, CRA referred to the situation where:
a return is due for an individual who lacks competency to sign, and over whom no one has Power of Attorney (for example, a child or spouse looking after a parent or spouse’s affairs on an informal basis, or a deceased taxpayer where no Executor or Administrator has been legally appointed).