In 2013-0474111I7, the Rulings Division advised a local Tax Services Office that an acquired company could not reverse prior-year CCA claims so as to revive expired losses. The facts indicated that in taxation years before the company was acquired, it had claimed CCA which in turn resulted in business losses. These business losses survived the loss-streaming rules in s. 111(5) when control of the company was acquired, but those losses subsequently expired in the ordinary course. The company subsequently asked the CRA if it could amend prior year filings so as to reverse the CCA claims. The businesses losses would instead be realized on the acquisition of control (under the write-down rule in s. 111(5.1)), and would survive until a later year when they could be used. The Rulings Division denied the company’s request. The decision in Clibetre Exploration Ltd. v. The Queen, 2003 DTC 5073, was distinguished on the basis the issue (there) involved a legal re-characterization of ordinary expenditures into Canadian exploration expenses. Here the request was to reverse a permissive deduction (CCA) deliberately taken by the company in the earlier years. The Rulings Division further said that to allow the reversal of CCA (to reinstate the expired losses) would constitute “retroactive tax planning inconsistent with the specific provisions of the Act and the scheme of the Act as a whole”.