CRA will deny a request for a late-filed ETA s. 156 election where not all returns have been filed

Respecting a query on late-filed ETA s. 156 elections, CRA stated:

Under administrative tolerance, the CRA may consider a request to accept a late-filed election. These requests will be considered on a case-by-case basis. As a condition, Paragraph 4 of policy statement P-255 specifies that all GST/HST returns must be filed by all parties to the election, and, that the parties must be fully compliant with the GST/HST legislation. Where GST/HST returns are outstanding, or a registrant is non-compliant, the request to accept this election will be denied.

Neal Armstrong. Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.4 under ETA s. 156(4)(b)(ii).