Chapter

CRA confirms that CUEC computed in the first (EIFEL) regime year using a 40% ratio must for carryforward purposes be recomputed using the 30% ratio

From Colubriale v. Canada, 2005 FCA 329 by Un actionnaire vend un immeuble à sa société

Concepts

  1. Excess Capacity

    "Regarding the situation where one member of a pre-regime group had September 30 taxation year ends and significant excess capacity for EIFEL purposes compared to other members of the group, which had

CRA confirms that CUEC computed in the first (EIFEL) regime year using a 40% ratio must for carryforward purposes be recomputed using the 30% ratio | Colubriale v. Canada, 2005 FCA 329 | Bifalgorithm | Bifalgorithm