5 October 2018 APFF Roundtable Q. 15, 2018-0768861C6 F - Share exchange and statute of limitation -- summary under Effective Date

CRA accepted that where a price-adjustment clause retroactively adjusts a tax attribute, such as adjusted cost base, that arose from a rollover transaction that occurred in what is now a statute-barred year, that adjustment may occur “for a taxation year that is otherwise not statute-barred if it has an impact on the tax consequences for that year.”