The appellant appealed the assessment of penalties under subsection 162(7) of the Income Tax Act for failing to file T1135 Foreign Income Verification Statements on time for the 2019 and 2020 tax years.
The Tax Court of Canada held that while a due diligence defence is available for subsection 162(7) penalties, the appellant failed to establish it.
Having previously made a voluntary disclosure for the same issue, a reasonable person in her circumstances would have taken greater care.
The appeals were dismissed.
