Generally speaking, the Fairness Rules allow the Canada Revenue Agency discretion to
cancel or waive penalties and interest;
Therefore, all tax advisors should review those situations where there may be the possibility that there will be a fairness request, and the request should be made by December 31, 2004. Once this deadline has passed, it will be impossible to request relief for the years 1985 to 1994.
On a go-forward basis, the Fairness Rules will only apply for the previous ten years. For example, in the year 2008, the fairness request can only go back to 1998.
A careful review of all files should be done.
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