In essentially confirming 2009-0351721E5 to the effect that an associated group of Canadian-controlled private corporations can file amended T2 Schedule 23s provided that the amended allocation agreement does not change the amount allocated to any associated corporation for a taxation year for which a reassessment is statute-barred, CRA stated:
[P]aragraph 125(3.2)(d) provides that both CCPCs must file a prescribed form with the Minister in their return of income for their respective taxation years for the assignment to be valid.
The CRA will generally accept the amended forms detailing the assignment of the business limit provided the amendments do not result in a change in the business limit for a taxation year of any taxpayer for which a reassessment is statute-barred.