The taxpayer referenced the statement in IT-474R, para. 10 that “[w]here the provisions of paragraph 87(2)(a) produce unintended consequences … the Corporate Rulings Directorate … is prepared on a case by case basis to consider whether relief is appropriate.” After indicating that this statement was not a basis for requested relief from the short taxation year (which had not been anticipated) resulting from an amalgamation producing an additional administrative burden, CRA stated:
[W]e have previously allowed an amalgamated corporation to make the subsection 20(24) election, even though technically it could only be made by the predecessor corporation, since it was the predecessor corporation, and not the amalgamated corporation, that had included in its income for a taxation year an amount in respect of undelivered goods or services pursuant to paragraph 12(1)(a).