March 11, 2025
Summary: On February 28, the CRA announced that it was pushing back the deadline for all T slips issuers to electronically submit their slips until March 7, the end of the first two weeks of the income tax and benefit (ITB) return filing season. This meant that CVITP volunteers could not depend on the Autofill My Return (AFR) service to reliably provide all a client’s T slips. Anyone wanting their ITB return done in the first two weeks would need to present paper T slips to their return preparer to make sure all their sources of income were declared. Further adding to the confusion, the CRA waited until the end of the first of those two weeks to inform CVITP volunteers and other users of EFILE of this deadline change. As if that wasn’t bad enough, the CRA’s announcement was written in a way that made it hard to understand exactly what was going on.
In the past, I have argued that AFR is a great innovation and is preferable to simply relying on paper slips. If the CRA really wants CVITP volunteers to use it, then it should avoid measures like the one it took early in this tax filing season which seriously damage its reliability.
On Friday, February 28, anyone with EFILE authorization, including all CVITP volunteers got a message from the CRA which indicated it was providing penalty relief for all returns of information, at the very least until March 7.
This was a confusing messaging. But a careful reading of the email revealed that the CRA was letting issuers delay electronically submitting T slips to the CRA until Friday, March 7. Only after that date would they be charged a penalty for late submission.
This meant that the AutoFill My Return (AFR) function would not show all the T slips one would expect to see at the beginning of the income tax and benefit (ITB) return filing period on February 24. This was certainly my experience in the first two weeks of the season. The AFR service revealed incomplete accounts in over half my clients’ cases. I know this because my clients had the foresight to bring their paper T slips to their appointments. AFR was effectively an unreliable source of information for the first two weeks. Better to rely on paper slips.
Clinic coordinators less familiar with the way AFR works or who simply did not understand the CRA’s message might not have forewarned their volunteers to ask clients for paper slips to ensure they declared all their clients’ income. In the past, I have found AFR useful for identifying income the client has forgotten to mention. Under these exceptional circumstances, there was simply no way a client interview could be completed and the ITB return filed with confidence that it was accurate if the client had forgotten to bring their T slips to the interview.
At the very least, the CRA should have sent this message to EFILERS on or before February 24 – the beginning of the tax filing season – rather than waiting until the end of the first week of the season. In its absence, CVITP volunteers discovered quite by chance that some T slips were missing.
At the same time, the CRA could have made its message clearer. It could have indicated that many T slips would not be available and that those using EFILE during the penalty relief period should make sure to ask their clients to bring their paper T slips to their interview. (As most clients appeared to have their paper slips, the problem seemed to be solely with issuers sending the information electronically to be entered into the CRA’s database.)
Why didn’t the CRA consider delaying opening the tax filing season until all the T slips were in the system? If somewhat disruptive, this solution would have ensured that the AFR function remained a reliable tool for getting all the T slips.
The CRA message contained no explanation for why it had instead offered this extension. It could have explained to EFILERS the reasons behind this unanticipated change.
In another sign the CRA is undermining the usefulness of the AFR function, the CRA indicated at the beginning of this season that the AFR service now no longer includes the uncashed cheques indicator. This is unfortunate as this was a useful function when it was introduced for the 2024 tax season. Why did the CRA do this? Once again, the CRA gave no explanation for this change.
If the CRA values its volunteers, it should communicate in a more transparent way. This would show the CRA treats its volunteers as important collaborators and not just useful instruments in the CRA’s ITB return filing process.
The results of the CRA CVITP 2023 survey – the results of the 2024 survey which was taken in May 2024 have, at this date, still not been published online by the CRA – showed that only 38% of respondents used AFR. The poor CRA planning and communication we saw at the beginning of this year’s tax season will not improve the adoption of rate among many CVITP volunteers already reluctant to use the AFR function. Many already felt the AFR function was confusing and time consuming to use. The actions taken by the CRA at the beginning of this season will only reinforce their conviction that AFR is not reliable and that they should continue to copy the information manually into the return using their clients’ paper slips.
In the past, I have argued that AFR is a great innovation and is preferable to simply relying on paper slips. If the CRA really wants CVITP volunteers to use it, then it should avoid measures like the one it took early in this tax filing season which seriously damage its reliability.