7 October 2016 APFF Roundtable Q. 1A, 2016-0652951C6 F - Penalty late filed election-subsection 85(8) -- summary under Subsection 85(8)

Is the late election penalty under s. 85(8) applied on a property-by-property basis? CRA responded:

Where a taxpayer transfers several properties at a given date to a taxable Canadian corporation, the CRA's policy is to calculate the penalty under subsection 85(8) based on all the properties that appear on the prescribed form T2057… that is filed late, and not property by property, in the case where one form is filed.