Bulk Taxpayer Relief Requests & Relief For Extreme Weather Events

Published date13 December 2021
Law FirmSpenceDrake Tax Law
AuthorMr Cris Best

Canada Revenue Agency (CRA) released guidance on "bulk" taxpayer relief requests as well as taxpayer relief for "extreme weather events." CRA makes specific reference to the "unprecedented floods in British Columbia and Eastern Canada." Taxpayers, including individuals, businesses and first responders, may fail to meet their tax filings obligations as a result. According to CRA:

When an extraordinary event (for example, natural disaster) has prevented many taxpayers from meeting their tax obligations, the minister may issue a news release to announce that special consideration will be given to providing relief, such as a waiver or cancellation of penalty and interest charges on late tax remittances or late filing of a return. In such cases, taxpayers need to ask to get relief.

Bulk Taxpayer Relief Request

A bulk request refers to a representative submitting one taxpayer relief application on behalf of multiple taxpayers based on "common reasons and similar facts." An example would be the British Columbia floods. In this instance, related delays filing tax returns and paying tax owing can result in penalties and interest. Interest will accrue as long as there are penalties and tax owing.

CRA will accept a bulk taxpayer request for relief from penalties and interest for consideration under the following conditions:

  • The request describes common reasons for seeking relief;
  • The facts and circumstances apply to all taxpayers; and
  • No taxpayer-specific information is required to render a decision.

Taxpayer relief is generally granted when the following types of situations prevent a taxpayer from meeting their tax obligations:

  • extraordinary circumstances;
  • actions of the CRA;
  • inability to pay or financial hardship;
  • other circumstances

If a bulk taxpayer relief request was submitted for a group affected by the BC floods, it would presumably be based upon facts establishing extraordinary circumstances and inability to pay or financial hardship. Per CRA policy, extraordinary...

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