20 June 2016 External T.I. 2016-0651951E5 F - Amalgamation - non-capital loss of new corporation -- summary under Subsection 87(2.1)

The loss, sustained in the year after the amalgamation, of the corporation formed by the amalgamation of two sister corporations cannot be carried back to reduce the taxable income of either predecessor corporation in light especially of s. 87(2.1)(e).