CRA indicates that s. 50(1) elections must be made on a debt-by-debt basis

CRA stated that, since whether a debt has become uncollectible is a factual determination respecting each debt, the “election provided for in subsection 50(1) must therefore be made separately for each debt.” S. 33(2) of the Interpretation Act (“the singular include[s] the plural”), was not discussed.

However, CRA indicated that the election must be made by attaching a signed letter to the return, and that “there appears to be nothing in the legislation to prevent several separate elections, for each of the debts in question, from being set out in a single letter.” Effectively, CRA seems to be saying that a single s. 50(1) election letter can be attached for a multitude of debts, provided that they are listed.

Neal Armstrong. Summary of 1 April 2026 Internal T.I. 2025-1050651I7 F under s. 50(1).