21 November 2011 External T.I. 2011-0416881E5 F - Late-filed designation - paragraph 88(1)(d) -- summary under Paragraph 88(1)(d)

CRA generally allows a late-filed designation under s. 88(1)(d) to the extent that (1) the parent corporation agrees to allocate the excess calculated under s. 88(1)(d) proportionately among the capital properties eligible for the bump on the basis of the limit available under s. 88(1)(d)(ii); or (2) the parent accepts that CRA will determine, at its discretion, to which property the excess amount should be allocated. CRA will not accept a late-filed designation where (1) there is retroactive tax planning; (2) the designation is part of a tax avoidance scheme; or (3) it is necessary to issue a reassessment for a statute-barred year to effect the designation (being generally the year in which the properties were disposed of.)