"A TPR to revise the amount of a reserve claimed in a particular taxation year will not be permitted if the reserve was based, at the time it was claimed, on what was considered to be a reasonable amount.\n\nIf a taxpayer requests a revision to a permissive deduction claimed in a taxation year after the time for filing a notice of objection has passed, such a request will only be considered if\n\nit was made within the normal or extended reassessment period, as applicable, and\n\nit is accompanied by a request for an offsetting change in another permissive deduction such that no change occurs in the assessed tax for that taxation year or any other year for which the time limit for filing a notice of objection has expired.\n\nExamples of where the latter exclusion could apply include\n\nwhere the change would affect an amount reported in a subsequent year as recapture of depreciation or a terminal loss,\n\nwhere the TPR is made by a successor corporation to reduce the amount of resource expenditures claimed by an original owner or predecessor owner in a prior taxation year,\n\nwhere the TPR adjustment would impact amounts already deducted or reported under s. 80,\n\nwhere the TPR adjustment would impact amounts reported on a previously filed s. 85 or 97(2) election,\n\nwhere the relevant assets are no longer owned at the time of the request,\n\nwhere the request would “contravene a specific provision of the ITA or the scheme of the ITA as a whole” (para. 69), or\n\nwhere the TPR relates to adjustments to CCA or other permissive deductions for taxation years prior to an acquisition of control."