Chapter 11 .xlsx - Acquisition of Control Rules 251.2(2)...

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Acquisition of Control Rules251.2(2)Loss restriction event256(7)Acquiring ControlFour things to consider1) Have to have an accounting - deemed year end before acquisition date - 249(4)aUCC = TAX COST for DEPRECIABLE ASSETS
Capital Losses, ABILs, Property Losses - falls off the table - new purchaser does nCan claim Operating Losses after acquiring control, only if these thr1) Must carry on the loss business2) Must have a reasonable expectation of profit3) Can only use loss to agains imcone from that loss bLook at all assets with inherent lossdeemed to sell all accounts with inherent lossesallowed to use capital losses that fall off111(4)aDenies Capital Losses111(4)eDesignate the disposal of capital (between FMV and T111(5)Non- Capital Losses and Streaming Rulesif a business wno amount ofno carryforwardexcept
not have these losses on a carryforward basisree conditions are metbusiness or similar businessff the table

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1981, 1986, 1983

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