Sale of Tax Losses The Act contains many provisions that are designed to ensure that a corporation’s tax losses cannot be used by unrelated [or sometimes unaffiliated] persons unless they continue to carry on the corporation’s business with a reasonable expectation of profit. However, these loss restriction rules generally only apply when the unrelated persons […]
Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations Series 4: Businesses Folio 7: Wind-ups, Dissolutions and Amalgamations Chapter 1: Amalgamations of Canadian Corporations Summary This Chapter outlines the Canada Revenue Agency’s (CRA) views on a number of issues relating to the amalgamation of two or more taxable Canadian corporations as described in subsection 87(1) (referred to in this
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NO: IT-243R4 DATE: February 12, 1996 SUBJECT: INCOME TAX ACT Dividend Refund to Private Corporations REFERENCE: Section 129 (also sections 51, 84, 85.1, 86, 87, 88, 105, 123.2, 125, 150, and 157; subsections 12(10.2), 15(3), 85(1), 104(13) and (14), 126(1) and (2), 161(2), 186(2), 256(2), and 260(7); the definitions of “designated property” and “private corporation” in
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