CRA might not be authorized to carryforward an unreported SDA benefit to the first non-statute-barred year

S. 6(11) effectively provides that a deemed benefit “shall be included” in an individual’s employment income in the year in which a right under a salary deferral arrangement arises. CRA considers where there was a failure to report such an inclusion, the amount can be included in income by reassessment of the individual's first year that is not statute-barred.

“The Act provides no such statutory election to the minister” to change the year of required inclusion of the benefit.

Neal Armstrong. Summary of David Nathanson, "Included Versus Reported," Canadian Tax Highlights, Vol. 24, No. 9, September 2016, p. 5 under s. 6(11).