CRA finds that pre-acquisition-of-control net capital losses of a CCPC continue to grind its CDA
15 November 2012 - 11:59pm
CRA has confirmed that net capital losses of a CCPC, which are extinguished for most purposes upon an acquisition of its control, nonetheless will continue to be deducted in computing its capital dividend account: the worst of both worlds.
Neal Armstrong. Summaries of 5 October 2012 APFF Roundtable, Q. 8, 2012-0454161C6 F under s. 89(1) - CDA, and s. 245(4).