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In applying this factor, external influences such as economic conditions may affect the sale of artistic or literary works, will be taken into consideration. 1.25 No particular factor described in ¶1.24 is more important than another …. 1.26 In the case of an artist or writer, it is possible they may not realize a profit during their lifetime. ...

Consequently, transactions that occur sequentially on the same day but prior to the amalgamation will be reported by the predecessor corporation in the tax year that is deemed to have ended immediately before the amalgamation. 1.17 …Where the duration of…short tax years of the predecessor corporations would be a matter of days, for instance where the normal tax year-ends are December 31 and the amalgamation takes place on January 2, and where there would be adverse implications in having short tax years, consideration should be given to requesting the Minister's concurrence to extend such year-ends…. ...

"In situations such as those in ¶1.63.1 but where the debt represents only partial consideration for the share acquisition, if some assets do not meet the purpose test, the taxpayer may adopt a flexible approach in linking the debt to the eligible assets formerly held by the acquired corporation.... ...