CRA finds that a taxpayer cannot request a notice of determination of loss until after audit

Contrary to an interpretation favoured by the Department of Finance, CRA considers that a notice of determination of loss cannot be made by the Minister in response to a request made by the taxpayer at the time of originally filing its return, so that such determination can only be made after the Minister has adjusted the amount of the reported loss on audit.

Neal Armstrong. Summary of 18 November 2014 TEI Roundtable, Q. E.1, 2014-0550351C6 under s. 152(1.1).