CRA warns that s. 12(13)(b) has no continuity rules for common reorganization transactions

CRA planted a repeat of the similar question posed in 10 October 2024 APFF Roundtable, Q.1 in order to then be able to warn that there are no continuity rules for common reorganization transactions, such as amalgamations, s. 88(1) wind-ups or s. 85(1) rollovers in the s. 12(3)(b) flipped property rule, so that such an event or transfer starts the 365-day period in s. 12(13)(b) running again.

Neal Armstrong. Summary of 3 December 2024 CTF Roundtable, Q.12 under s. 12(13)(b).