Before noting that non-capital losses of inactive corporations likely could not be carried forward following an acquisition of their control “because of the prior cessation of activities of the corporations concerned,” CRA stated:
[W]here a subsequent business of a corporation is of the same nature as the first, but the owners are different, it is our view that the two businesses will not normally be considered to be the same business where the first business ceases to operate before the second begins to operate.