The Court in Chen v Canada (Attorney General), 2019 FC 1435, seemed to accept that a taxpayer, to avoid late-filing penalties, could have filed a T1135 with estimates in it before the deadline and then filed an amended return later.
This suggestion would seem to live in tension with a previous CRA statement to the effect that a “substantially incomplete or inadequate return” would not prevent it imposing late-filing penalties or reassessing beyond the normal reassessment period even if it had issued a notice of assessment in response to the offending return.
