Is the CRA's position, that a predecessor corporation whose control was acquired on the same day will have only one year end, solely limited to the situations described IT-474R2, para. 11 and 2004-0105481? If not, when will a predecessor corporation, whose control was acquired on the same day, and that carries out or is involved in transactions on the day of the amalgamation, have only one year end?
CRA responded:
In general, the CRA applies the administrative position described in paragraph 11 of Interpretation Bulletin IT-474R2, only where the acquisition of control and the amalgamation are the only transactions occurring outside the ordinary course of business of the predecessor corporations that are carried out on the day of the amalgamation. In that regard, we consider, as being outside the ordinary course of a corporation's business, any transaction described, for example, in a closing agenda for the date of closing or in any other document describing a logical order in which transactions must be carried out in anticipation of the amalgamation of a predecessor corporation.
It appears to us more appropriate in general that legal transactions by the predecessor corporations be reported by the same predecessors rather than by the amalgamated corporation.