CRA indicates that the penalty for late-filing information slips references when the last slip was filed

The penalty under s. 162(7.01) for late-filing most types of information slip (e.g., the T3, T4, T4A, T5, NR4 or T4RSP) is calculated under a formula which references the number of late-filed slips and “the number of days, not exceeding 100, during which the failure continues.” CRA considers that “the failure” continues until the last slip of a particular type is filed. Thus, if 73 T5 slips are filed a few days late but a 74th slip is filed 56 days late, the penalty is calculated in the same manner as if all 74 slips had been filed 56 days late.

Neal Armstrong. Summary of 15 August 2018 Internal T.I. 2018-0748441I7 under s. 162(7.01)(b).