2 February 2006 External T.I. 2005-0152431E5 F - Utilization of non-capital losses -- summary under Subparagraph 256(7)(a)(i)

Ms. A, who owned all the shares of Lossco, which had disposed of all the assets of its (unspecified) business for cash, disposed of those shares for FMV cash consideration to Profitco, which was owned equally by her and her three siblings. CRA indicated that s. 256(7)(a)(i) would apply.