2 December 2011 External T.I. 2011-0424446E5 - Interaction of Subsections 249(3.1) and 249(4) -- summary under Subsection 249(3.1)

on November 30, a Canadian-controlled private corporation (Corp A) and a non-resident enter into a purchase agreement, with the non-resident closing the purchase of Corp A later in the day. No election is made under s. 256(9), so that the taxation year of Corp A which commenced on January 1 is deemed by s. 249(4) to end at the end of November 29.

By virtue of s. 249(3.1)(a) and s. 251(5)(b), Corp A would have a second taxation year commencing at the beginning of November 30 and ending immediately before the signing of the sale agreement. Accordingly, Corp A would continue to be a Canadian-controlled private corporation for such (second) taxation year.

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Drupal 7 entity type
Node
Drupal 7 entity ID
307843
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
344350
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