Neal Armstrong is on a sarcasm roll this week. After noting that the CRA, in a recent interpretation (2014-0540611E5E), took the position that a 98(3) election is valid only if it is made for all property of the partnership and that the election can’t be amended, he writes:
Brilliant! This accords with the principle of statutory interpretation that the literal words of a provision should be applied mechanically, in the same way that a computer would run a piece of applications software [citation not available].
