A taxpayer has no requirement to pay. It provides an additional penalty otherwise provided for in the Act. Any Judge upholding the provisions, as it presently stands, would have to be Mentally-Bankrupt or a Lunatic. One must remember Revenue Canada is not a financial institution authorized, in law, to charge interest. The exercise is simple.
Parliament can then later amend the provisions as it sees fit.
In the interim, upon receipt of such an assessment, it is recommended you file a Notice of Objection accordingly and proceed to have the court strike down the provisions in its present form. I can send them to you along with a copy of the flyer .