I have a client with a large sale (close to $10M) - occurred 11 days into the new year
They have never paid corporate tax and therefore the instalment base from prior year T2 is zero.
I believe that they are not technically required to remit instalments but I wanted to check in with the ProTax community to see if there are differing views on the requirements.
The need to remit instalments is based on what the tax liability will be for the upcoming year. Even if you had an instalment base from the prior year, it’s still just an estimate. The interest levied on missed instalments (or payments that were less than required), can’t be determined until the corporate tax liability is actually known for that year.
For example:
If your client had a sale in 2021, for a corporate year end of Dec 2021, and there was no requirement to make instalments for 2021, there will be no interest levied for instalments that were not made during 2021.
If the corporation has no taxable income for 2022, there would be no requirement to remit instalments in 2022, even if they get a notice from CRA “suggesting” amounts that “should” be remitted during 2022. If the corporation has taxable income for 2022, the REQUIRED instalments will be based on the actual tax liability for 2022, which may be different than the SUGGESTED instalments, calculated earlier in the year.
Sorry Nezzer. There is no instalment interest in 2 situations. 1, pay the instalments suggested by CRA - there is no interest even if the taxpayer owes tax after paying the instalments. 2. pay no instalments or your best guess which is less than suggested - interest is charged on any shortfall up to the suggested instalments.