2007 Ruling 2006-0198421R3 - Utilization of Losses - Acquisition Control -- summary under Paragraph 111(5)(a)

Ruling that following the transfer by Lossco of a business to a partnership of which it was part owner and an indirect acquisition of control of Lossco, the business of Lossco will now be carried on through the transferee partnership, so that the Lossco streamed losses may now be deducted by the amalgamated successor to Lossco under paragraph 111(5)(a) provided that such business is carried on for profit or with a reasonable expectation of profit throughout the particular taxation year of the amalgamation corporation in which the Lossco losses are deducted.