INTEREST CALCULATION – LOSS SUBSTITUTIONS
In a March 21, 2018 Technical Interpretation (2017-0736291E5, Godson, Gillian), CRA stated that they would not charge interest when there is a substitution of losses (e.g. a loss carryforward replaced with a loss carryback) for a particular tax year that does not result in a change in tax payable. Absent this administrative concession, interest could be calculated from the balance due date of the taxation year to which the loss is applied until 30 days after the amendment was filed (Paragraph 161(7)(b)).
For further information see Video Tax News Monthly Tax Update Newsletter, Issue No. 445.