Bill C-47 introduced a requirement that certain remittances or payments to Receiver General be made electronically if the amount exceeds $10,000. For income tax, subsection 160.5(2) requires that remittances or payments exceeding $10,000 be made by "electronic payment" unless the payor or remitter "cannot reasonably remit or pay the amount in that manner." The penalty for failure to remit or pay electronically when required is $100 for each failure.
The CRA has made the following statement concerning their approach to administering penalties relating to electronic payments introduced under C-47:
"The CRA has established an administrative approach to not run enforcement measures with the application of penalties related to electronic payments introduced under Bill C-47; ample advance notice will be provided when/if this approach changes. In the meantime, the CRA will continue to educate taxpayers on electronic payment offerings and encourage taxpayers to pay electronically wherever possible; regardless of the amount. Payments made through a bank or credit union are considered to be made electronically for this purpose as well as any payments made online via online banking, CRA's portal services and/or services provided by third-party service providers. "
Information on payment options can be found at Canada.ca/payments.
Originally posted on LinkedIn on June 4, 2025
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Ryan Minor
Chartered Professional Accountants of Canada
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