An unrelated CRA assessment of a business limit assignee might invalidate that assignment

The above post on 2017-0713051E5 notes that CRA has a solution (through filing an amended business-limit assignment) when at the time required for the first CCPC to file the assignment it does not yet know what is the maximum permitted assignment amount because the year end for the second (assignee) CCPC has not yet been determined. A similar issue has not yet been addressed by CRA, namely, that the income of the second CCPC might subsequently be reduced due to an assessment (e.g., because CRA applied s. 67 to deny the deductibility to the first CCPC of fees charged to it by the second CCPC – see 2012-0440071E5). This income reduction would retroactively reduce the allowed BL assignment amount, which might invalidate the assignment,

At some point, CRA presumably will be asked whether in this situation as well, an amended assignment can be filed.

Neal Armstrong. Summary of Dino Infanti, "Assignment of Small Business Limit Creates Filing Headaches," Tax for the Owner-Manager (Canadian Tax Foundation), Vol. 18, No. 1, January 2018, p 3 under s. 125(3.2).