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 Chopp v. R., 98 DTC 6014, [1998] 1 CTC 407 (FCA) by Sambif

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

  2. Capacity Recalculation

    "In particular, CRA confirmed that the corporate group would need to determine any pre-regime excess capacity and any first regime year’s excess capacity twice: once using the 40% ratio of permissible

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 | Chopp v. R., 98 DTC 6014, [1998] 1 CTC 407 (FCA) | Bifalgorithm | Bifalgorithm