CRA (sort of) reverses an interpretation indicating that s. 110.5 income adjustments potentially may be made for statute-barred years

In 2013-0481151I7, CRA indicated that, by analogy with the CCA revision policy in IC 84-1, an adjustment under s. 110.5 (to effectively convert what otherwise would be a wasted (for FTC purposes) foreign tax amount into a non-capital loss) may be made even beyond the six-year s. 152(4)(b)(iv) reassessment period "where there is no change in the tax payable for the year."  However,"tax" included provincial taxes, so that a requested adjustment under s. 110.5 for a statute-barred year would not be permitted if it increased provincial taxes payable - and 2010-0379801I7 suggested that this usually (or always?) would be a problem.

CRA (without explanation) has now "clarified" that "a permissive amount in the context of IC84-1 would not…include the income inclusion provided in section 110.5."

Summary of 7 February 2014 Memo 2013-0512601I7 under s. 152(4).