Does s. 249.1(7) provide the Minister with the discretion to allow a taxpayer’s request to change the taxpayer’s fiscal period end (“FPE”) where the taxpayer’s return has been assessed, or if the taxpayer has filed the return but it is still not assessed? After indicating that where a taxation year has already been assessed on the basis of a fiscal period end, the Act does not have any provision that allows a reassessment to change the FPE, the Directorate went on to state:
[T]he … [preamble] wording of subsection 249.1(1) indicates that the purpose of specifying a particular period of time as a fiscal period is that a corporation can choose, within the parameters specified under the subsection, a FPE for preparing its accounts for the purposes of assessment. In general, where a corporation has filed its first income tax return, but an assessment is still to be made, the provisions of the Act do not appear to prevent the corporation from sending an amended tax return with a new FPE.