This case involves Banff Caribou Properties Ltd., which requested that the Minister of National Revenue accept amended tax returns to elect certain depreciable capital properties as separate classes of eligible non-residential buildings. The election would allow Banff Caribou to deduct a capital cost allowance at a rate of six percent instead of the four percent rate it had been deducting before 2017. However, the Minister refused to accept the late-filed election letters, and Banff Caribou asked the Court to review this decision. The Court found that the Minister's refusal was reasonable and that the Income Tax Act and Regulations do not provide the Minister with the discretion to accept late-filed election letters under the relevant subsection. The Court also noted that Banff Caribou's arguments were not persuasive in rebutting the relevant presumption, and the application for judicial review was dismissed.