CRA provides transitional relief for 2-tier joint ventures
When CRA withdrew its position allowing joint ventures to compute income as if they had a separate fiscal period, it also indicated that it would allow transitional relief by allowing the deferred income to be brought into income over a period of up to five years (similar to the rule in s. 34.2).
CRA has indicated that this administrative transitional relief also will apply to the the full amount of the deferral of 22 months' worth of income that was deferred as a result of a two-tier joint venture (e.g., the corporate taxpayer is a member of a joint venture with a fiscal period ending one month later which, in turn, is the member of a second joint venture with a fiscal period ending yet a further one month later).
Neal Armstrong. Summary of 28 August 2012 T.I. 2012-0454811E5 under s. 249.1(1).