CRA not providing relief where COVID-related delays create difficulties in meeting deadline for s. 164(6) loss carrybacks within estate’s first taxation year
In CRA Technical Interpretation 2020-0865071E5, the CRA was asked whether it would allow more time for the application of s. 164(6) of the Income Tax Act (Canada) where COVID has resulted in delays regarding the administration of an estate. The CRA indicated it is “unable to extend the time limit for the dispositions in subsection 164(6) … beyond the first taxation year of the graduated rate estate.”