Principal Issues: Whether a CCRB claimed under subsection 127.421(2), being related to a specific period and deemed to be received at a time specified by the Minister of Finance that is after the end of that specific period, should be considered to relate to a pre-bankruptcy 2023 taxation year, a post-bankruptcy 2023 taxation year, or both.
Position: The interpretation that best reconciles subsection 127.421(2) with paragraph 128(1)(d) is that the CCRB be treated as a payment on account of Part I tax payable for the first taxation year ending in the 2023 calendar year. In a bankruptcy context, this would generally be the pre-bankruptcy taxation year.
Reasons: Section 127.421 is structured to limit an eligible corporation to one CCRB per calendar year, calculated based on factors for a calendar year, which is claimed through the filing of a return of income for a particular taxation year. This limitation, and the proposed amendment to extend subsection 127.421(11) to apply for the purposes of subsection 127.421(2), supports the interpretation that a CCRB claim cannot relate to both taxation years of a bankrupt ending in a calendar year.
January 8, 2026
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Income Tax Rulings
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J. Clarkson
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