Estate and trust

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

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Bradley Morse
Morse Brewster Lake
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Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

I've had CRA assess a penalty for failing to include Schedule 15 with the first T3 return filed after the 36-month GRE period ended. In our case, we requested taxpayer relief and CRA cancelled the penalty (although when they cancelled the penalty, they did not apply the cancellation to the account balance properly so the SIN is still showing an amount payable and subsequently the clearance certificate is being held up).

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

Emily, can I ask what reason you put when you requested relief? We have a similar situation that we are submitting shortly so it's good to know when a human puts eyes on it they are being reasonable. 

I've had CRA assess a penalty for failing to include Schedule 15 with the first T3 return filed after the 36-month GRE period ended. In our case, we requested taxpayer relief and CRA cancelled the penalty (although when they cancelled the penalty, they did not apply the cancellation to the account balance properly so the SIN is still showing an amount payable and subsequently the clearance certificate is being held up).

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

Kimber - In our situation, the original executor of the estate was also terminally ill and passed away a few months after we filed the first non-GRE T3 return. When her executor contacted us for assistance with both estates, she provided a Notice of Assessment showing the s.15 penalty, along with a collections notice. After investigating, we discovered that the mailed T3 return (which wasn't eligible for EFILE) was missing Schedule 15. The schedule had been prepared, but our tax software's print settings didn't include it in the government copy for paper-filed returns - so it never made it into the package that went to CRA. In our taxpayer relief request submitted in September 2024, we explained the accidental omission and the original executor's illness and subsequent passing, which delayed our office being made aware of the CRA correspondence. CRA accepted the circumstances and granted relief in July 2025. Hope that helps!

Emily, can I ask what reason you put when you requested relief? We have a similar situation that we are submitting shortly so it's good to know when a human puts eyes on it they are being reasonable. 

I've had CRA assess a penalty for failing to include Schedule 15 with the first T3 return filed after the 36-month GRE period ended. In our case, we requested taxpayer relief and CRA cancelled the penalty (although when they cancelled the penalty, they did not apply the cancellation to the account balance properly so the SIN is still showing an amount payable and subsequently the clearance certificate is being held up).

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

Thanks for the additional information. Great that your client was granted relief. I am curious, though, as to why the return was not eligible for EFILE.  BTW, I checked the default print settings in Taxprep/Cantax and Schedule 15 is set to print "If applicable" in the Govt print format.  

Kimber - In our situation, the original executor of the estate was also terminally ill and passed away a few months after we filed the first non-GRE T3 return. When her executor contacted us for assistance with both estates, she provided a Notice of Assessment showing the s.15 penalty, along with a collections notice. After investigating, we discovered that the mailed T3 return (which wasn't eligible for EFILE) was missing Schedule 15. The schedule had been prepared, but our tax software's print settings didn't include it in the government copy for paper-filed returns - so it never made it into the package that went to CRA. In our taxpayer relief request submitted in September 2024, we explained the accidental omission and the original executor's illness and subsequent passing, which delayed our office being made aware of the CRA correspondence. CRA accepted the circumstances and granted relief in July 2025. Hope that helps!

Emily, can I ask what reason you put when you requested relief? We have a similar situation that we are submitting shortly so it's good to know when a human puts eyes on it they are being reasonable. 

I've had CRA assess a penalty for failing to include Schedule 15 with the first T3 return filed after the 36-month GRE period ended. In our case, we requested taxpayer relief and CRA cancelled the penalty (although when they cancelled the penalty, they did not apply the cancellation to the account balance properly so the SIN is still showing an amount payable and subsequently the clearance certificate is being held up).

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

In the same week that we got our first NORA back with the reversal of the late filing penalty of the Sch 15, we received a 2024 NOA dated Oct 29, 2025 assessing the max $2,500 penalty with the same issue. We use Taxprep and the Sch 15 was filed on time. 

The NORA stated  "because of a processing error, our records did not match the information you previously gave us." 

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

I'm using Cantax, E-filed the T3 on time with what I thought was set to file the Sch 15 as well.  CRA is telling me now they never received the Sch 15 and assessing the $2,500 penalty.  I've got of no way (I assuming) to prove that the Sch 15 was sent with efile.  Hopefully they will grant relief for the penalty - told me it would take at least 9 months to review. 

In the same week that we got our first NORA back with the reversal of the late filing penalty of the Sch 15, we received a 2024 NOA dated Oct 29, 2025 assessing the max $2,500 penalty with the same issue. We use Taxprep and the Sch 15 was filed on time. 

The NORA stated  "because of a processing error, our records did not match the information you previously gave us." 

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

I'm using Cantax, E-filed the T3 on time with what I thought was set to file the Sch 15 as well.  CRA is telling me now they never received the Sch 15 and assessing the $2,500 penalty.  I've got of no way (I assuming) to prove that the Sch 15 was sent with efile.  Hopefully they will grant relief for the penalty - told me it would take at least 9 months to review. 

In the same week that we got our first NORA back with the reversal of the late filing penalty of the Sch 15, we received a 2024 NOA dated Oct 29, 2025 assessing the max $2,500 penalty with the same issue. We use Taxprep and the Sch 15 was filed on time. 

The NORA stated  "because of a processing error, our records did not match the information you previously gave us." 

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?

Is anyone having issues with CRA not receiving Schedule 15 and charging $2,000 penalties?