CRA finds that two deposit-taking businesses satisfied the similar business test in the loss-streaming rule

CRA ruled that a deposit-taking business of a financial institution that was acquired by and amalgamated with another financial institution would satisfy the similar business test in the loss-streaming rule in s. 111(5)(a), so that its non-capital losses could be utilized.  This ruling likely turns on the proposition that the profitable Amalco financial "services" business would entail the "rendering of similar services" to those for the acquired business.

Neal Armstrong.  Summary of 2011 Ruling 2011-0392171R3 under s. 111(5)(a).