1.42 Where the new corporation is not related to the predecessor corporation, subsection 100(2.1)… requires the predecessor corporation to...

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1.59 Where control of a corporation is acquired and that corporation makes a designation under paragraph 111(4)(e) to realize an accrued foreign...

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1.82 Where the shares of a predecessor corporation were taxable Canadian property of a non-resident shareholder, the postamble to subsection...

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1.35 Where one predecessor corporation has a leasehold interest in a property owned by a second predecessor corporation, the application of...

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1.64 If an assessment (or reassessment) of a predecessor corporation is made after amalgamation, it will usually be issued to the new corporation...

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1.63 If an assessment (or reassessment) has been received by a predecessor corporation prior to amalgamation and the predecessor corporation has...

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1.95 A person entitled to a reserve under paragraph 20(1)(n), subparagraph 40(1)(a)(iii) or subparagraph 44(1)(e)(iii) in respect of an amount...

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1.7 Subsection 248(1) defines a shareholder to include a member or other person entitled to receive a dividend. Therefore, a person can be a...

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1.32 …[S]ubsection 251(3.1) deems the new corporation formed on an amalgamation to be related to (and, therefore, not deal at arm's length...

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1.49 Pursuant to subparagraph 256(7)(b)(i), control of a corporation will be deemed not to have been acquired solely because of an amalgamation...

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1.95 A person entitled to a reserve under paragraph 20(1)(n), subparagraph 40(1)(a)(iii) or subparagraph 44(1)(e)(iii) in respect of an amount...

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1.56 In the case of an amalgamation to which subsection 87(1.2) does not apply, any undeducted balance in a predecessor corporation's resource...

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1.98 In the case of an amalgamation or merger, there may not technically be a disposition of property from a predecessor corporation to the new...

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1.81 Subsection 87(5) does not apply where an employee holds rights under an agreement to acquire shares of a predecessor corporation and...

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1.92 …The provision applies where an indebtedness (including a distress preferred share), as referred to in subsection 80.01(3), owed by one...

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1.5 …[S]ubsection 84(3) will not otherwise apply to deem a shareholder of a predecessor corporation to have received a dividend where the...

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1.61 If the laws governing an amalgamation provide that the predecessor corporations are continued in the amalgamated corporation, the...

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1.9 … Subsection 87(1.1) deems the shares that are not cancelled on a short-form vertical or horizontal amalgamation to be shares of the new...

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1.56 In the case of an amalgamation to which subsection 87(1.2) does not apply, any undeducted balance in a predecessor corporation's resource...

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1.79 In certain amalgamations, the shares of a predecessor corporation which were listed on a designated stock exchange may be temporarily...

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1.78 On an amalgamation described in [s. 87(11)], a capital gain may arise for the parent. Specifically,… if the paid-up capital of the...

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1.4 In Envision Credit Union v. R., 2013 SCC 48, 2013 DTC 5144 (SCC), the Supreme Court of Canada held that it was not possible for the...

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New corporation

1.13 Under the corporate law in most jurisdictions, the corporate entity formed as a result of an amalgamation is a continuation...

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1.27 …The new corporation will generally be expected to follow the inventory valuation method adopted by its predecessor corporations for the...

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1.98 In the case of an amalgamation or merger, there may not technically be a disposition of property from a predecessor corporation to the new...

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1.30 …[T]he capital cost to the new corporation of depreciable property of a prescribed class acquired by it on the amalgamation will equal the...

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1.42 Where the new corporation is not related to the predecessor corporation, subsection 100(2.1)… requires the predecessor corporation to...

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1.46 Where a corporation has granted an option (other than an option to acquire its shares, bonds or debentures), subsection 49(1) deems the...

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1.67 Pursuant to paragraph 87(2)(q), the new corporation is deemed to be the same corporation as, and a continuation of, each predecessor...

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1.52 …[T]he new corporation formed on a qualifying vertical amalgamation can apply its post-amalgamation losses against the pre-amalgamation...

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1.54 Where...where a subsidiary's losses have been carried forward to the parent under the provisions of subsections 88(1.1), (1.2) or (1.3),...

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1.88 When a new corporation has more than one class of shares, a proportional reduction of paid-up capital under subsection 87(3) may, in certain...

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1.87 Although subsection 87(3) limits the aggregate paid-up capital of the issued shares of the new corporation, there is no specific provision...

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1.69 For greater certainty, the rollover under subsection 87(4) is not available to shareholders whose shares of a predecessor corporation are...

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1.58 Since paragraph 87(7)(d) provides that the provisions of the Act apply as if the new corporation had incurred or issued the debt at the time...

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1.12 … In general terms, this [s. 87(9)(c)(ii)] additional amount is equal to the amount by which the tax cost of the assets (less liabilities)...

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1.39 …[T]he designation of any bump amount must normally be made in the new corporation's Part I income tax return for its first tax year....

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1.54 Where a predecessor corporation's losses have been carried forward to the new corporation under the provisions of subsection 87(2.1), it is...

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1.43 …[W] here a Canadian partnership ceases to exist because of an amalgamation involving one or more of the corporate partners:

• subsection...

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1.31 …[T]he half-year rule found in subsection 1100(2) of the Regulations will apply in determining the new corporation's maximum capital cost...

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1.31 …[T]he half-year rule found in subsection 1100(2) of the Regulations will apply in determining the new corporation's maximum capital cost...

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1.33 …[W]here a predecessor corporation was not dealing at arm's length (otherwise than because of a right referred to in paragraph 251(5)(b))...

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1.67 Pursuant to paragraph 87(2)(q), the new corporation is deemed to be the same corporation as, and a continuation of, each predecessor...

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Requirement for Amalco year end not to skip a year

1.17.1 … [A] fiscal period of a corporation can be up to 53 weeks. However, subsection 249(3)...

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Amalco can make s. 22 election (if no business interruption)

1.62.1 Where a new corporation that was formed on an amalgamation that was governed...

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