Foreign spin-offs - Extension under the taxpayer relief provisions of the Income Tax Act

A legislative amendment to the Income Tax Regulations extends the application of the taxpayer relief provisions to the election that allows a tax deferral of eligible distributions of foreign spin-off shares. Among other things, the taxpayer relief provisions give the Minister of National Revenue and his delegated officials discretion to allow late and amended elections, or to revoke them. Since 2005, an application must be made within ten years of the end of the tax year to which the election relates.

Section 600 of the Regulations has been amended to add paragraph 86.1(2)(f) to the list of elections set out in paragraph 600(c). As a result, the Minister of National Revenue may, under the taxpayer relief provisions of subsection 220 (3.2) of the Income Tax Act, extend the time for making the election for a tax deferral of eligible distributions of foreign spin-off shares.

Related topics

• Taxpayer relief provisions
• IC07-1, Taxpayer relief provisions