Subsection 5903(3)
See Also
Trans World Oil & Gas Ltd. v. The Queen, 95 DTC 260 (TCC), briefly aff'd 98 DTC 6060 (FCA)
A U.S. resident corporation ("Trans World U.S.") that incurred business losses while it was owned by a Canadian-resident individual and then was...
Administrative Policy
21 October 1992 Memorandum (Tax Window, No. 27, p. 13, ¶2345; October 1993 Access Letter, p. 476)
Where the amalgamation of two unrelated taxable Canadian corporations precedes the merger of their respective wholly-owned U.S. subsidiaries under...