Taxpayer relief RC4288: three grounds, 10 calendar years back

Which situations qualify, and what evidence goes with each?

The CRA can cancel or waive penalties and interest when events beyond your client's control stopped them from meeting a tax obligation, and it sorts requests into three grounds plus a catch all canada.ca. Each ground has its own evidence list on the how to apply page, and a request without it tends to come back with a letter asking for more canada.ca.

Two limits catch accountants. Errors or delays by a representative or other third party are generally your client's responsibility, not a ground for relief canada.ca. And for hardship, the circular says cancelling a penalty because of an inability to pay "would not generally be considered", with extreme business financial difficulty as the stated exception canada.ca.

How far back does a 2026 request reach?

Ten calendar years, counted two different ways. A penalty qualifies only if it relates to a tax year or fiscal period ending in the 10 calendar years before the year of the request, while interest qualifies if it accrued in those 10 calendar years canada.ca. The window rolls forward every January 1 canada.ca.

Worked example. Your client owes a 2014 balance. The CRA assessed a $1,500 late filing penalty for 2014, and interest has run on the debt ever since: say $700 accrued in 2015 and $6,300 from 2016 to the date of the request. A request filed in 2026 reaches back to 2016 (2026 minus 10). The 2014 penalty is out, because the 2014 tax year ended outside the window. The 2015 interest is out too. The most the CRA can relieve is the $6,300 of interest, even though the debt dates from 2014. Wait until January 2027 and the 2016 interest drops out as well.

The statute counts from the year end itself: the Minister can act on or before the day that is ten calendar years after the end of the taxation year, or on an application made by then laws-lois.justice.gc.ca. For a corporation with a March 31 year end, file by March 31 of the tenth year rather than waiting for December. If an audit or objection may run past the limit, send a protective request now and the details later canada.ca.

How do you file the request?

Online is the faster route to the queue. For an individual, sign in to My Account or Represent a Client, open Accounts and payments and choose Request relief of penalties and interest. For a business, use My Business Account or Represent a Client, pick the program account (GST/HST or income tax, for example) and the same service canada.ca.

On paper, complete Form RC4288 and mail it to the office listed on the last page of the form for your client's province or territory canada.ca. The current form page was updated May 19, 2025, and the fillable PDF has to be opened in Adobe Reader, not a browser canada.ca.

Either way, give the CRA account number (SIN, business number, trust or partnership number), every tax year or period involved, and a detailed account of how the event stopped your client from paying, filing or complying on time canada.ca. The CRA weighs your client's compliance history, whether they knowingly let a balance sit and accrue interest, whether they took reasonable care, and how quickly they fixed the problem canada.ca. Say why the event caused the default, not only that it happened. You can only discuss the request with the CRA once your client has authorized you.

What happens while the CRA decides?

As of October 2026, requests take about 16 months on average, because of a high volume of applications. Complex files, several tax years or programs, and incomplete documents push that out. Track the status in the Progress Tracker in My Account, My Business Account or Represent a Client canada.ca.

Interest keeps accruing on the balance during the review, so paying all or part of it now limits the cost. If relief is granted, the CRA generally refunds cancelled amounts your client already paid, with interest where applicable, though the refund can be applied to other debts or held for missing returns canada.ca. For the rate that interest runs at, see the CRA interest rate on overdue taxes.

If the assessment behind the penalty is under objection or appeal, the CRA won't make a final relief decision until that dispute is resolved and all appeal rights have expired canada.ca. Relief never touches the assessed tax itself. To dispute the tax, file a notice of objection on its own deadline canada.ca. To correct a return your client filed, use CRA change my return instead.

What if the CRA says no?

You can't object. Subsection 165(1.2) bars an objection to an assessment made under 220(3.1) laws-lois.justice.gc.ca. The recourse runs in two steps.

Ask for the second review first: the CRA recommends it before going to court canada.ca. Point to the information that was missed or misread, and add any new documents. The circular confirms the court can extend the 30 days, but don't plan on it canada.ca.

GST/HST, VDP and penalties relief cannot reach

GST/HST relief comes from Excise Tax Act s.281.1, which uses the same 10 calendar years counted from the end of each reporting period laws-lois.justice.gc.ca. The online request is filed under the GST/HST program account in My Business Account canada.ca.

Some amounts are outside the program altogether: assessed tax, anything older than the 10 year window, administrative charges like bank chargeback fees, and penalties the CRA has no legal power to waive, such as the GST/HST gross negligence penalty under s.285 of the Excise Tax Act canada.ca.

If the real problem is an unfiled return or unreported income the CRA hasn't found yet, taxpayer relief is the wrong tool. The Voluntary Disclosures Program uses the same s.220(3.1) authority but has its own form, conditions and relief levels. For a late T2 with no underlying event to point to, start with the T2 late filing penalty rules. Once the CRA has assessed the repeated failure to report income penalty, relief is open only on the grounds above.