Can an insurer elect under Reg. 2411(3)(a) subsequently to filing its income tax return? CRA responded:
There is no specific provision for the acceptance of a late filed election under paragraph 2411(3)(a)… .
The court cases and the Rulings opinions…[respecting] late filed designations under paragraph 55(5)(f) or subsection 104(13.1)… can be distinguished from an election under the Act. … Administratively, there is no requirement that the CRA extend the taxpayer relief provisions to elections other than those listed in section 600 of the Regulations.