Section 66.7

Table of Contents

Section 66.7
Subsection 66.7(2) - Successor of foreign exploration and development expenses
Administrative Policy(1)
Subsection 66.7(3) - Successor of Canadian exploration expense
Administrative Policy(3)
Articles(1)
Subsection 66.7(5) - Successor of Canadian oil and gas property expense
Administrative Policy(1)
Subsection 66.7(7) - Application of s. 29(25) of ITAR and ss. (1), (3), (4) and (5)
Administrative Policy(3)
Subsection 66.7(10) - Change of control
Articles(1)
Paragraph 66.7(10)(j)
Cases(1)
Administrative Policy(1)
Articles(1)
Subsection 66.7(16) - Non-successor acquisitions
Articles(2)

Subsection 66.7(2) - Successor of foreign exploration and development expenses

Administrative Policy

13 November 1991 T.I. (Tax Window, No. 13, p. 5, ¶1593)

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Subsection 66.7(3) - Successor of Canadian exploration expense

Administrative Policy

11 August 2020 Internal T.I. 2018-0782181I7 - Successored CCEE and Non-Capital Losses

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(c) s. 3(c) deduction (e.g., under s. 67.3) cannot generate a non-capital loss 92
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense successored resource expenses are not deductible under s. 9 165

94 C.P.T.J. - Q. 11

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31 August 1992 Memorandum (Tax Window, No. 23, p. 16, ¶2165)

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Articles

Carr, "The Successor Corporation Rules after Bill C-18", 1992 Canadian Tax Journal, No. 6, p. 1261.

Subsection 66.7(5) - Successor of Canadian oil and gas property expense

Administrative Policy

10 October 2006 Internal T.I. 2006-0169051I7 - Successor Pool Issues

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Subsection 66.7(7) - Application of s. 29(25) of ITAR and ss. (1), (3), (4) and (5)

Administrative Policy

S4-F7-C1 - Amalgamations of Canadian Corporations

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 113
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 167
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 132
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 157
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 103
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 88
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 172
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) related party, majority and 50% group exceptions 495
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 113
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 112
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 165
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 87
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 66
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 120
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 55
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 297
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 758
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 113
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 149
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 139
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 169
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 44
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 346
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 189
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 281
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 191
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 230
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 122
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 62
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 137
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 467
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 371
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 327
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 249 - Subsection 249(3) 136
Tax Topics - Income Tax Act - Section 22 - Subsection 22(1) 179

12 June 1992 Memorandum (Tax Window, No. 21, p. 9, ¶2019)

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90 C.P.T.J. - Q.35

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Subsection 66.7(10) - Change of control

Articles

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39

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Paragraph 66.7(10)(j)

Cases

Devon Canada Corporation v. The Queen, 2013 TCC 415

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Words and Phrases
reasonably attributable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) source preservation in 2-tier partnership 84

Administrative Policy

15 March 2012 External T.I. 2012-0432931E5 - Partnership property of successor corporation

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Articles

Marshall Haughey, "Tiered Partnerships: Successor Rules", Canadian Tax Highlights, Vol. 22, No. 2, February 2014, p. 13.

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(16) 227

Subsection 66.7(16) - Non-successor acquisitions

Articles

Brian R. Carr, "Devon Canada Corporation v. The Queen", Resource Sector Taxation (Federated Press), Vol. IX, No. 4, 2014, p. 677.

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Marshall Haughey, "Tiered Partnerships: Successor Rules", Canadian Tax Highlights, Vol. 22, No. 2, February 2014, p. 13.

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