CRA may not impose a penalty for late-filing a s. 116 application if the property was not sold at a gain

After finding that a child of a diplomat was not exempt from the s. 162(7) penalty for late-filing a s. 116 application, CRA stated that "you may wish to consider exercising discretion in assessing the penalty given that ... there was a loss on the property."

Neal Armstrong.  Summary of 17 February 2014 Memo 2013-0498121I7 under s. 162(7).