CRA is deliberating on how to relax its procedures for s. 221.2 re-appropriation requests

CRA recognizes that, following Cybernius Medical and Pomeroy’s Masonry, it will need to change its current procedures for dealing with re-appropriation requests under s. 221.2. Those procedures have the effect of denying such requests except in quite narrow circumstances. It has started deliberating, and there will be clarity in 2018 on this issue.

Neal Armstrong. Summary of 20 November 2017 CTF Annual Conference - CRA Panel on Issues in the Administration and Enforcement of the ITA, Q.10 under s. 221.2.