In light of the current measures for countering the impacts of COVID-19 (coronavirus), the governments of Québec and Canada has announced the following flexibility measures with respect to filing income tax returns.
Content updated on March 31, 2020.
GOVERNMENTS OF CANADA, QUEBEC & OTHER PROVINCES
- The deadline for filing income tax returns has been extended to June 1, 2020. For individuals in business, the filing deadline remains June 15, 2020.
- For individuals and individuals in business, the deadline to pay balances due regarding the 2019 taxation year is extended to September 1, 2020 (federal and Quebec). This measure also applies to instalment payments due on June 15, 2020. These amounts will not be subject to interest or penalties during this period.
- The deadline for filing trusts’ income tax returns that had to be filed after March 18, 2020 (applicable to December 31, 2019 year-end in Quebec) has been extended to May 1, 2020.
- The deadline to pay balances due regarding these tax returns is extended to September 1, 2020 (federal and Quebec). This measure also applies to instalment payments due on June 15, 2020. These amounts will not be subject to interest or penalties during this period.
- The corporate tax filing deadlines (T2) have been extended to June 1, 2020 for tax returns that were due after March 18, 2020 (federal and Quebec).
- In Quebec, the payment of instalments and income tax due March 17, 2020 and after, has been suspended until September 1, 2020. For federal purposes, payment of amounts due March 18, 2020, has been suspended until August 31, 2020. The payment date and terms will be announced later. These amounts will not be subject to interest or penalties during this period.
- These measures only apply to amounts that became due as of March 18, 2020 (March 17, 2020 in Quebec). Thus, a corporation having a December 31, 2019 year-end whose tax balance became due on February 29, 2020 (two months after the end of the year) is not eligible for these measures, unlike a corporation (SME) whose tax balance becomes due on March 30, 2020.
- Revenu Quebec will accelerate the processing of requests for tax credits intended for businesses and tax refunds.
- The filing deadline for partnerships information returns (T5013 and TP-600) is extended from March 31, 2020 to May 1, 2020 (federal and Quebec).
- At the federal level, the deadline for filing any registered charity information return (T3010) that had to be filed between March 18, 2020 and December 31, 2020 is extended to December 31, 2020.
NR4 INFORMATION RETURNS
- The filing deadline is postponed to May 1, 2020.
ELECTION FORMS AND OTHER ADMINISTRATIVE OBLIGATIONS
- The deadline for filing returns, forms, elections, designations (including rollovers and T1134s) and responses to information requests required under the ITA due after March 18, 2020 is extended to June 1, 2020 (federal and Québec).
- For federal purposes, this deferral does not apply to prescribed forms, receipts, documents and information with respect to SR&ED claims (expenses and credits). Quebec has not announced any specific measure in this regard.
- Payroll deductions and related activities must continue to be done on time (except for the reduction of payments relating to the temporary wage subsidy offered to SMEs in respect of income tax withholdings remittance on the salaries they paid).
GST/HST & QST
- The federal government and Quebec have extended to June 30, 2020 the time that :
- Monthly filers have to remit amounts collected for the February, March and April 2020 reporting periods;
- Quarterly filers have to remit amounts collected for the January 1, 2020 through March 31, 2020 reporting period;
- Annual filers, whose returns or instalments are due in March, April or May 2020, have to remit amounts collected and owing for their previous fiscal year and instalments in respect of the filer’s current fiscal year.
- This measure is also applicable to custom duty payments.
- In Quebec, the deferral applies both to the payment and the filing of QST returns.
- No relief was announced regarding the Quebec insurance tax.
It is unclear whether the deadline for filing GST/HST return is postponed. The federal government only mentioned payment, but Revenu Québec states, in its Information Bulletin 2020-5, that “The federal government has announced today that it is postponing the deadline for filing GST/HST returns and the attendant payments payable during the period starting March 27, 2020 and until June 1, 2020. In such cases, the deadline is postponed to June 30, 2020.” We are monitoring the situation and we will update this document if the federal government publishes clear instructions in this regard.
PROVINCES OTHER THAN QUÉBEC
- The payment extensions announced at the federal level will apply to provincial income tax in those provinces where the federal government collects tax, i.e. in provinces other than Québec and Alberta. This latter province has announced that corporate income tax balances and instalment payments will be deferred from March 19 until August 31, 2020.
- The CRA will not contact any SME businesses to initiate any post assessment GST/HST or income tax audits until mid-April. For the vast majority of businesses, the CRA will temporarily suspend audit interaction with taxpayers and representatives.
- Revenu Québec is suspending all tax audit and collection activities and the organization will show greater flexibility in respect of payment agreements for tax debts.
- CRA is suspending collection activities on new debts; collection staff will address pre-existing situations on a case-by-case basis to prevent financial hardship. Revenu Quebec is suspending all collection activities.
- CRA and Revenu Quebec will offer flexible payment arrangements to taxpayers.
- At the federal level, a taxpayer that is prevented from making a payment when due, filing a return on time, or otherwise complying with a tax obligation because of circumstances beyond their control, can submit a request to cancel penalties and interest.
OBJECTIONS AND APPEALS
- At the federal level, any objection related to benefits and credits identified as a critical service will continue as usual. Objections related to other tax matters filed by individuals and businesses are suspended. No collection action will be taken with respect to these accounts during this period of time.
- The Tax Court of Canada is closed until March 30, 2020. All timelines prescribed for appeals are extended.
- Revenu Québec and the CRA have confirmed that they will allow tax preparers to use an electronic signature on Electronic filing authorization forms (TP-1000.TE-V for individuals and CO-1000.TE for corporations in Quebec and Federal Form T183).
For more information, you can consult Revenu Québec’s website..