CRA is willing to adapt a prescribed requirement, that an election be made by letter attached to the return, to internet filings

A taxpayer must file an election pursuant to Reg. 1101(5b.1) for each eligible non-residential building for which the taxpayer intends to claim the additional CCA. CRA rejected the suggestion that classification of a qualifying non-residential building in a separate Class 1(a) or 1(b) on the taxpayer’s return was sufficient for the it to be considered to have made the election, noting that the text of Reg. 1101(5b.1) effectively indicated that the “taxpayer must … send to the Tax Centre … a letter attached to the taxpayer's income tax return stating the taxpayer's election for each eligible non-residential building for the taxation year in which the subject building is acquired.” However, CRA further stated:

[I]t is possible for the taxpayer to make the election under subsection 1101(5b.1) I.T.R. over the Internet using either of the following methods:

• by using the "T2 Attach-a-doc" service
• indicating this election in the notes to the financial statements in the General Index of Financial Information (GIFI) of the tax return.

Neal Armstrong. Summary of 7 October 2022 APFF Federal Roundtable, Q.4 under Reg. 1101(5b.1).