CRA finds that s. 220(3.2) does not accommodate requesting a late rescission of a s. 45(2) election

In finding that s. 220(3.2) does not accommodate a taxpayer request to extend the time for rescinding an election made pursuant to s. 45(2), CRA noted:

• although s. 45(2)(c) provides the potential for a taxpayer to rescind a s. 45(2) election, this is accomplished either by claiming CCA in a particular taxation year (in which case the rescission is effective on the first day of that year), or upon reporting a deemed disposition of the property resulting from the change in use pursuant to the rescission;
• thus, given their different legal effects, it followed that “rescinding” an election under s. 45(2)(c) could not be equated with “revoking” an election pursuant to s. 220(3.2); and
• to boot, the decision to rescind an election under s. 45(2)(c) did not itself constitute an election listed in Reg. 600.

Neal Armstrong. Summary of 5 January 2026 Internal T.I. 2025-1082101I7 F under s. 45(2)(c).