Administrative Policy
28 February 2019 CBA Roundtable, Q.24
Two registrants (Corporations A and B) amalgamate to form AmalCo, which immediately thereafter sells all its assets to a registered third party....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 167 - Subsection 167(1) | election unavailable where a newly-formed Amalco immediately transfers its assets | 202 |
23 March 2017 CBA Commodity Taxes Roundtable, Q.11(b)
Corporation A is assessed for its failure to have charged GST/HST on inter-corporate supplies of management services to Corporation B, which was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(a) | Amalco can issue invoice on behalf of one predecessor re purchase by another predecessor | 95 |
23 March 2017 CBA Commodity Taxes Roundtable, Q. 5
As a result of the merger of USCo1 into USCo2 with USCo2 as the survivor (“MergeCo”), all of the assets of the Canadian branch business of...
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 20. ("Reorganizations - Amalgamations")
Shares of Newco, which was incorporated solely for the purposes of purchasing all of the business assets of a supplier, are sold to a third party...
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 167 - Subsection 167(1) | not available if immediate amalgamation of recipient | 321 |
24 February 2011, CBA/CRA GST Round Table, Q. 15 - "Amalgamation & Successor Corp's ITC Entitlement"
In a corporate reorganization involving a GST registrant that is engaged exclusively in commercial activities, assets are first transferred to a...
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | if predecessor denied ITC, Amalco may be able to claim basic tax content | 174 |
| Tax Topics - Excise Tax Act - Section 206 - Subsection 206(2) | 173 |
GST/HST Memoranda Series 2.7 Cancellation of Registration May 2005
•If two or more corporations amalgamate, the successor company is a new entity and is considered to be a person separate and distinct from each...
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(6) | 78 |
GST M 200-8 "Cancellation of Registration"
Where two corporations amalgamate, their registrations should be cancelled and the amalgamated corporation may have to apply to be registered.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 242 - Subsection 242(1) | 0 |