Aco and Bco are each associated with Cco (also, a CCPC), but would not be associated with each other in the absence of s. 256(2)(a). Cco annually elects under s. 256(2)(b)(ii) not to be associated with Aco and Bco. Is 2003-0051701I7, which considered that by making such election, corporations were not associated for purposes of s. 125(5.1), but remained associated for the purposes of ss. 181.1(2) and (4), still applicable given that the proposed amendment does not apply to the taxation years in issue? CRA responded:
[T]he proposed amendment to subsection 125(5.1) does not affect the validity of the position taken in the situation set out in technical interpretation 2003-0051701I7.
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|Tax Topics - Income Tax Act - Section 256 - Subsection 256(2) - Paragraph 256(2)(b) - Subparagraph 256(2)(b)(ii)||s. 256(2)(b)(ii) election inapplicable for ss. 181.1(2) and (4) purposes||28|