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
- 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
- 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