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of <h1>Section 398 makes deductors/collectors assessee in default, limits deeming periods, adds safe harbour and two-tier interest</h1> The enacted Section 398 deems a person required to deduct or collect tax an assessee in default for failure to deduct/collect or, having done so, to pay; provides a narrow safe harbour where the recipient files a return, includes the amount and pays tax and the deductor/collector produces an accountant's certificate; prescribes two-tier simple interest for delay (lower rate until collection, higher thereafter); creates a charge on the person's assets for unpaid deducted/collected tax; limits deeming orders to six years or two years after a correction statement; and bars penalty unless the assessing officer is satisfied there were no good and sufficient reasons. Key drafting differences with the original bill: a cross-reference to a different correction-statement provision and the bill's omission of 'collect' from the penalty clause, which may narrow penalty protection for collectors.
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