The Directorate noted that pursuant to s. 152(1.2), the normal reassessment period rules in s. 152(4) also essentially were applicable to redeterminations made to s. 152(3.4). Furthermore, s. 125.7(16) did not allow the Minister to extend those periods for making such a redetermination in relation to a taxpayer’s request to amend an s. 125.7 application for a qualifying period.
The Directorate also indicated that s. 125.7(16) applies to initially filed applications and does not apply to requests to amend applications, so that it does not accord the Minister with the discretion to allow an eligible entity to amend or revoke a previously made election under s. 125.7.