2 June 2000 Internal T.I. 2000-0016087 F - SECTION DE LA LOI128(2)E -- summary under Subparagraph 128(2)(g)(i)

The Directorate indicated that non-capital losses incurred by an individual prior to the individual’s discharge from bankruptcy could not be deducted by the trustee (acting as agent for the individual) under s. 128(2)(e)(ii)(B) after such discharge of the bankrupt, given that s. 128(2)(g)(i) specifically provides that pre-discharge losses of an individual are not deductible in computing taxable income for a taxation year ending after the discharge, notwithstanding ss. 128(2)(e)(ii) and 128(2)(f)(iii). S. 128(2)(h) does not change this treatment since it applies only to taxation years beginning after the release and, furthermore, does not provide that the individual's discharge is to be disregarded.