Filing nil returns to avoid penalties

Can taxpayers, by filing nil returns, avoid late-filing penalties and begin the beginning of the normal reassessment period? The CRA says ‘no’ in technical 2014-0519701I7. The CRA says that, even if it issues a notice of assessment in response to the filing of such a tax return, it can still impose late-filing penalties or gross negligence penalties and assess beyond the normal reassessment period, if an amended return is filed later that makes it clear the original return was substantially incomplete or inadequate.