Demand to File

A demand to file is a formal notice from the Canada Revenue Agency, issued under subsection 150(2) of the Income Tax Act, requiring a taxpayer to file an outstanding return by a specified date. The CRA typically sends a demand when it can see — from information slips reported to it — that a taxpayer had income but did not file. A demand to file carries practical consequences beyond the obligation itself: failing to comply can lead to the repeat-failure penalty under subsection 162(2) and can support a prosecution for failure to file under subsection 238(1). A demand also affects access to the Voluntary Disclosure Program, because a disclosure made after the CRA has demanded a return may no longer qualify as "voluntary," which is one of the program's core conditions. Acting before a demand is issued generally preserves more options.