Gagnon v R, 2022 TCC 139 (informal procedure), provides a good review of the provisions of the Act, and related case law, that govern whether interest and penalties are payable by an individual who fails to remit installments in a timely manner or in adequate amounts.
Interestingly, the Court left open the possibility that a taxpayer who chooses not to use the “no calculation” option, and therefore who remits deficient installments, but who receives income late in the year that is unexpected, might be excused from paying interest and penalties anyway (see ΒΆ32). The Court held that the exception did not apply to the taxpayer in Gagnon, however.
