16 October 1990 Ruling 902293 F - Subsidiary's Expenditure Year - Transfer of Accounts to Parent on Winding-up

By services, 18 January, 2022
Official title
Subsidiary's Expenditure Year - Transfer of Accounts to Parent on Winding-up
Language
French
CRA tags
88(1.3)(a), 88(1)(e.3)
Document number
Citation name
902293
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633180
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-10-16 08:00:00",
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Main text
  October 17, 1990
Current Amendments and Rulings Directorate
Regulations Division L.A. McCarron-McGuire
  957-2092
Attention: B. Bryson
  902293

SUBJECT:  Paragraph 88(1.3)(a) of the Income Tax Act (the "Act")

We are enclosing a copy of a recent response to an inquiry concerning the above-noted provision of the Act.

In our view, the omission in paragraph 88(1.3)(a) of a reference to the "expenditure year" of the subsidiary does not allow for the proper operation of paragraph 88(1)(e.3) in situations where the parent corporation was not in existence at the end of the subsidiary's "expenditure year", as that term is defined in subparagraph 88(1)(e.3)(i).

Yours truly,

M.A. Hiltz for Director GeneralReorganizations and Non-resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch