Finance “will consider situations where the application of [s. 220(3.5)] late-filing penalties creates a disproportionate burden on low-income taxpayers”

When queried about the onerous impact on middle-class individuals of being required under s. 220(3.5) to pay a late-filing federal penalty of $100 per month for a late-filed election, e.g., under s. 50(1), 86.1 or 45(2), Finance stated:

As part of the ongoing review of the ITA rules, the Department of Finance Canada will consider situations where the application of late-filing penalties creates a disproportionate burden on low-income taxpayers.

Neal Armstrong. Summary of 6 October 2017 APFF Financial Strategies and Instruments Roundtable, Q.12 under s. 220(3.5).