In Telus Communications Inc. et. al. v. Canada (Attorney General), 2015 ONSC 6245 (copy attached), a corporate group filed a multi-tier alignment election in 2012 to align the fiscal year-end of two partnerships in the group. The group obtained prior confirmation from both Finance and the CRA that this election was available. The internal tax group then later discovered that the partnership structure included a third partnership, which invalidated the filed election. On an application for rectification, the Ontario Superior Court of Justice allowed the group to rectify the election – by permitting a transfer of the interest in the third partnership to a wholly-owned subsidiary effective December 31, 2011 (see paragraph 16). In doing so, the court applied the principles of rectification established in Juliar v. Canada (Attorney General), [I999] 46 O.R. (3d) 104 (Ont. S.C.) and Fairmont Hotels Inc. v. Canada (Attorney General), 2014 ONSC 7302. In the alternative, the court applied its “equitable jurisdiction to relieve persons from the effect of their mistakes”: TCR Holding Corp. v. Ontario, 2010 ONCA 233.