Estate and trust

We have a number of 164(6) elections in process and noticed that on the first blush CRA will only carryback enough of the losses to cover an CG and not against taxable income, then you have to file yet another T1 Adjustment to get the loss applied correctly.  No matter which way we apply it, our own way or CRA's recommended way, the elections are taking almost two years to get processed and for each one we have been submitting a service complaint which does expedite the claim and get it processed correctly - eventually. - but the cost of doing all of this adds up.

How were you requesting the s. 164(6) application to the terminal return? CRA has indicated that per the ITA you should be filing they an amended return (as opposed to a T1 Adjustment request). If an amended return is filed, then you can show the negative amount on line 12700 which should then be applied against other income.