Tax Payment Deadlines Extended, Again

Tax Payment Deadlines Extended, Again

On July 27, 2020 the Canada Revenue Agency (CRA) and Revenu Quebec (RQ) announced a further extension of tax payment deadlines from September 1, 2020 to September 30, 2020.

Per CRA:

The CRA is further extending the payment due date for 2019 individual tax returns and 2019 or 2020 corporation, or trust returns, as well as for instalment payments, from September 1, 2020, to September 30, 2020.

The previously-extended filing due dates for individual, corporation, and trust income tax returns remain unchanged. The CRA encourages everyone to file their income tax returns as soon as possible, even though payment deadlines are being extended. However, recognizing the difficult circumstances faced by Canadians, the CRA will not charge late-filing penalties where a 2019 individual return or a 2019 or 2020 corporation, or trust return is filed late as long as it is filed by September 30, 2020.

The extensions to the filing due date for income tax returns detailed below also apply to forms T106 and T1135, and any elections, forms, and schedules that must be filed with the return.

Per RQ:

For individuals and individuals in business, the deadline for paying income tax, contributions or the annual registration fee for the enterprise register related to the 2019 income tax return has been extended to September 30, 2020. If you are required to make instalment payments, the payments normally due on June 15 and September 15, 2020, are now due by September 30, 2020.

(For corporations and SIFT entities) Instalments and income tax balances that would have been due in the period between March 17 and September 29, 2020, are now payable by September 30, 2020.

(For trusts) The deadline for paying income tax or the annual registration fee for the enterprise register related to the 2019 (and 2020) income tax return… has been extended to September 30, 2020. If a trust is required to make instalment payments, payments normally due on June 15 and September 15, 2020, are now due by September 30, 2020.

A few things to note:

While CRA has indicated that this announcement does not extend the filing due dates for the returns, it has extended its administrative policy not to charge late filing penalties if the return is filed by September 30, 2020. RQ has not so indicated this for the filing of Quebec returns, so it may be prudent to ensure that Quebec returns still be filed by September 1, 2020.

Also note that CRA has extended the filing deadline for forms T106 and T1135 and any elections, forms and schedules that must be filed with the return. This would appear to indicate that the extension to September 30, 2020 does not extend to elections and designations that are not required to be filed with the particular tax return (e.g. form T2057 for elections under Section 85 of the Income Tax Act).

While the September 30, 2020 extension/interest relief applies for income tax payments, it does not apply to GST/HST, payroll tax nor non-resident withholding tax remittances (other than withholding taxes in respect of certain distributions to non-resident beneficiaries of a trust). However, CRA has confirmed that the September 30, 2020 extension does apply to income tax payments and late filing penalties for elective tax returns filed by non-residents under Sections 216 (rental income) and 217 (pension income) of the Income Tax Act.

As a final measure, CRA is applying interest relief to existing income tax debts (related to individual, trust and corporate tax returns) for the period of April 1, 2020 to September 30, 2020. Interest relief is also being applied to GST/HST debts for the period of April 1, 2020 to June 30, 2020.

Author

Don Scott, FCPA, FCA
Director of Tax Services, Partner
dscott@welchllp.com
613-236-9191 #515