4 November 2002 Internal T.I. 2002-0160697 F - REPARTITION DU PLAFOND -- summary under Paragraph 125(5)(a)

On February 7, 2000, control of Aco, was acquired by a third party, resulting in a deemed taxation year-end under s. 249(4) and in a second taxation year for 2000 ending on December 31, 2000, and in it now being associated with Zco, which had a December 31, 2000 taxation year-end. For its taxation year ending February 6, 2000, the business limit allocated was allocated between Aco and other CCPCs with which it was associated up to the acquisition of control.

The Directorate indicated that since Aco was not associated with the same corporation during its two 2000 taxation years, s. 125(5)(a) did not apply to restrict Aco's business limit for its taxation year ending on December 31, 2000.

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