(a) During the period 2000-01, the Minister of National Revenue received 571 so-called “constructive notices”. The minister received 274 during 2001-02, and 57 from April 1, 2002 to September 30, 2002. There is no reliable data for the periods prior to 2000. Similarly, the Canada Customs and Revenue Agency, CCRA, has no data with respect to the source of these “constructive notices” or where a client may have obtained instructions on their use.
(b) The CCRA does not keep statistics on the number of persons filing “constructive notices” in relation to their filing status and does not prosecute Canadians for filing a “constructive notice”. However if a client chooses not to file a return and not comply with a “requirement to file a tax return”, the client may then be prosecuted for the failure to file a required return.