Application of Multiple 162(7.01) and (7.02) Penalties on Different Types of Returns

In 2013-0515121E5, the CRA was asked whether the penalties in subsection 162(7.01) were applied for each separate type of return late-filed and whether the penalties in subsection 162(7.02) applied for each separate type of return not electronically filed.

The CRA’s view was that the number of returns under subsections 162(7.01) and (7.02) must be calculated in respect of the words “of a type” in each subsection.  As such, the subsections apply separately for each type of return filed either late or non-electronically.