A taxpayer proposed retroactively changing to using the cost-recovery method in accounting for a share sale on an earnout basis (apparently in a taxation year that was now beyond the normal reassessment period). Before finding that such a change was not justified for other reasons, CRA stated:
In general, the CRA does not accept the amendment, revocation or late-filing of an election if the election is not described in Regulation 600. That being said, an administrative policy is not a provision of the Act or a prescribed election. Thus, the cost recovery method, as well as subsections 12(1) and 40(1), are not part of the prescribed list of provisions, and therefore we are of the view that subsection 220(3.2) does not apply in such a situation.