Is the making of a late election generally accepted without application of the penalty of $100 per month if the absence of a timely election is attributable solely to ignorance of the availability of the election or of the occurrence of an eligible distribution? CRA stated (TaxInterpretations translation):
The CRA does not intend to provide systematic administrative relief in the situation described… . …Each submitted case must be reviewed on a case by case basis and the Minister has discretion in the making of her decision. This discretion [in ss. 220(3.1) and (3.2)] is exercised in light of the guidelines provided in Information Circular 07-1… .