I have efiled a blank return for a client who can’t find his NOA. I am hoping CRA will reassess it and provide him with a current NOA we can use going forward.
That could be considered fraud.
Yikes! Filing a return that is not approved by the client - especially one with NIL income (assuming neither approved and NOT actually NIL income)…..um…..wow. And if the client approved it…double yikes.
Suggest you CAREFULLY review the requirements for ANY return filed under Sec 150 of the ITA, and then read your Efiler’s agreement because I’d think it is contrary to the TOS of Efile and likely to the requirements of the Income Tax Act.
Filing a return is a LEGAL act and is not to be taken lightly.
I do have client’s approval to the plan.
CRA wants the returns, they need to make it so clients can file accurately. They serve us - not the other way around.
Knowingly filing a false return is, at a minimum, unprofessional. It doesn’t matter if the client approves, if you know that a return is false then you should not file it, even if the client wants you to.
Some CRA guidance.
If you can’t get a slip in time to file your taxes, you can estimate your income. Add up your pay stubs or financial statements to estimate the amount of income to report and any related deductions and credits you can claim.
Include a note with your return stating the name and address of the issuer of the slip, the type of income, and what you are doing to get the slip.
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If you file electronically: Keep all of your documents in case the CRA asks to see them later.
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If you file a paper return: Attach a copy of the pay stubs or statements and your note to your paper return. Keep your original documents.
Here’s another one - a bit different – hoping to hear how others are handling similar situations? Sorry if it’s wordy but I wanted to lay out all of the facts.
New client (to me) needs 2013 to 2024 filed (we’ll do 10 years).
Says he has MyAccount set up but cannot get into it?
Has filed before, but not since 2012, does not have any copies of old tax returns or Notices of Assessment.
I attempt to gain Authorization using the new RAC process, but don’t get the option to print out a manual authorization form, rather it asks me for figures from his 2012 tax return, which he does not have. I assume that this is due to the fact that he has actually filed tax returns in the past, rather than the other client example that I outlined way up above in this thread? ie. If they have filed a return before, the auth screen asks for the NOA value, if they haven’t filed, it presents the manual Auth form?
I ask him to call the CRA and attempt to reactivate his MyAccount service, he does, but CRA tells him that he cannot revive it until he files his past due tax returns?
He asks the CRA to send him copies of all his slips for the years in question so that I can use them to file his returns, since I cannot access his slips via RAC.
I will be able to complete his returns once he gets the copies from CRA, but I’d really like to have access to RAC, in case there are other bits of info up there that are pertinent?
Questions:
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Will I have to wait until 6 months after his returns have been assessed to attempt to Authorize him again using his Notice(s) of Assessment values from my filings?
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Will he then have to attempt to gain access to his CRA MyAccount after these returns are assessed, or will that happen automatically – I think I know the answer

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Is there any way to “force” the new RAC Authorization process to generate the manual authorization form if it skips directly over to the Notice Of Assessment line number amount screen?
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Any other tips for handling this type of situation?
Thanks in advance – very much appreciated!
This whole story tells me that we as tax prepares care sometimes more about filing a client’s return than they do. Right now I have a new client that is several years behind and has a lien against his employee income by CRA. I am several weeks later and still didn’t get his rent receipts. He can stop the lien once he files his tax returns because he will get money back. Unbelievable.
I would just take the T-slips and RRSPs slips the client gets from CRA and just file it. I don’t think there is away around the 6 month waiting period. But follow up in 6 months to get access.
The client might be able to get the 2012 NOA and try again?
I would have him get the 2012 assessment sent to him in the mail so you have the figure for authorization. In a simple situation you may be able to figure out the income for a guess at line 150 from the increase in RRSP room from the previous year, the details of which are available for many years back.
EDIT: I realize to see the RRSP information you need access to RAC. duh
Thanks Arliss, great suggestion!
I sometimes find that the NOA amounts are off by several dollars. Not sure why. Might it be because they round everything down? I have seen T4’s that I got from CRA where all the income amounts were rounded to zero cents even though I had the actual T4 with cents.
The system comes from an errar where 1 MB was a LOT of memory. They truncate the numbers. So 2.98 + 4.99 = 6.
I learned this by trying to hack the system when I had the client’s filing of the T1 but not the NOA.
True. The CRA drop the cents that we may have included on the line numbers.
You can if you have a power of attorney for the client. That is an alternate solution. Just saying….CRA has relegated us to licking stamps to request clients past NOA, NORA, slips and other information. We have form letters prepped for every new client and we have alot every year. This should drive up their workload and perhaps persuade them to revert back to the T183 submission. If there are bad actors then just punish them and not all 190,000 representatives.
Well I discovered today it doesn’t seem to matter what you upload. ![]()
Does that mean you got access or no?
Yes I was granted immediate access. I didn’t upload the correct paperwork. ![]()
I realized it after but the opportunity to upload the correct signature page disappears after upload.
Oh well. I am in. ![]()
A CRA agent 2 weeks ago told me to get a new to me client that has not filed in 10+ years to buy a simple tax software, file an all zero return to get a NOA , then get me to get authorization based on the all zero NOA and refile a corrected return to avoid the liability of me filing a blank incorrect returns….
I’m willing to bet that agent won’t be at CRA for very long. That is AWFUL advice.
Hey Mike,
Did you do this through RAC?
I have a new client that has 4 years worth of taxes to file, but she’s never filed before.
Is there a way to do it through RAC since I won’t have any previous line numbers to enter?