CRA really uses all that T1134/T1135 foreign reporting fodder

Whether CRA will apply the s. 162(5) penalty or the more significant 162(7) penalty when foreign reporting forms (e.g., T1134, T1135 or T1142) are incomplete depends on whether the form is merely "missing information which does not affect the substance of the form" or it instead "is substantially incomplete."  Why the fuss?

[T]he required information provided by the forms is entered into the Foreign Reporting Requirements Management System (FRRMS) by the [Ottawa Technology Centre]. The… information from the FRRMS provides the main risk assessment tool for Aggressive Tax Planning and international auditors.

Neal Armstrong.  Summary of 6 December 2013 Memo 2012-0458401I7 under s. 162(7).