for the CRA to waive penalties and interest and CRA has modified its rules as a result of the decision in Bozzer v. Canada (2011 FCA 186) where the Court clarified how to determine the ten year period.
"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."