CRA accepts that a designation (but not an election not listed in Reg. 600) can be made late

Reg. 2411 prescribes an amount which is intended to ensure that a multinational insurer’s net investment revenue derived from its designated insurance properties is not less than the net investment revenue that would be determined for that property if the average rate of return on its designated assets of each class equaled an average rate of return on all its investment property of each class.  Reg. 2411(3)(a) provides that in specified circumstances the insurer may elect in its return for a specific formula to be used for these purposes.

If this election is not made in the return, CRA will not accept a late election, given that it is not listed in Reg. 600.  It considers decisions on late-filed designations (e.g., Nassau Walnut, Lussier) to be inapplicable to late elections.

Neal Armstrong.  Summary of 14 May 2015 CLHIA Roundtable, Q. 3, 2015-0573861C6 under Reg. 2411(3)(a).