On July 17, 2008, the Minister issued a notice of intent to revoke the registration of a pension plan established by the taxpayer, with the proposed revocation to be as of June 1, 2001 (the date of the plan's initial registration) on the basis that there was no evidence that the plan had ever complied with Regulation 8502(8). On July 13, 2008, the administrator of the plan wrote to the Minister requesting that the revocation of the plan be as of August 31, 2008.
Subsection 147.1(12) authorized the Minister to specify June 1, 2001, as the date on which the Plan's revocation would be effective, as there was no basis for the Court to vary the date of revocation from that specified by the Minister. Giving effective priority to the Minister in determining the date of revocation recognized the Minister's responsibility for administering the Act.