26 September 1990 Income Tax Severed Letter ACC9606 - Flow Through of B.C. Venture Capital Tax Credits

By services, 22 July, 2022
Official title
Flow Through of B.C. Venture Capital Tax Credits
Language
English
Document number
Citation name
ACC9606
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656706
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-09-26 08:00:00",
"field_tags": []
}
Main text

3-70-60336-01-001

                                B. Fioravanti
19(1)                           (613) 957-2073
                                HBW 9359-11-3

September 26, 1990

Dear 19(1)

We are writing in reply to your letter of July 10 concerning the flow through of British Columbia venture capital tax credits. Since we administer the British Columbia Income Tax Act, the 24(1) has asked that we reply to you on their behalf.

We agree that unused venture capital tax credits earned by an amalgamating corporation flow through to, and may be utilized in accordance with the provisions of the British Columbia Income Tax Act by, the amalgamated corporation provided that the relevant corporate law provides for the continuance of the amalgamating corporation as the amalgamated corporation.

We do not agree that any unused venture capital tax credits earned by a subsidiary corporation are acquired, and may be utilized by, the parent corporation following the winding-up of the subsidiary into the parent corporation.

A winding-up involves the transfer to the parent of a subsidiary's assets and a dissolution of the subsidiary. Accordingly, the identity of the subsidiary corporation is not merged with that of its parent on the winding-up.

We trust that this will be of assistance.

Yours sincerely,

C. Savage Acting Director Provincial and International Relations Division

BF/jb no4-22 File copy Sequence file Author's copy Reading file Chrono File(2)