Income Tax Act — I-3.3 88
, (viii) “new corporation’s income” were read as “parent’s income”, (ix) “subsection 89(5)” and “subsection 89(9)” were read as “subsection 89(6)” and “subsection 89(10)”, respectively, (x) “any predecessor private corporation” were read as “the subsidiary (if it was a private corporation at the time of the winding-up)”, (xi) and (xii) [Repealed, 1994, c. 7, Sch. II, s. 66] (xiii) “two or more corporations” were read as “a subsidiary”, (xiv) and (xv) [Repealed, 1998, c. 19, s. 118] (xvi) “the life insurance capital dividend account of any predecessor corporation immediately before the amalgamation” were read as “the life insurance capital dividend account of the subsidiary at the time the subsidiary was wound-up”, (xvii) “predecessor corporation’s refundable Part VII tax on hand” were read as “subsidiary’s refundable Part VII tax on hand”, (xviii) “predecessor corporation’s Part VII refund” were read as “subsidiary’s Part VII refund”, (xix) “predecessor corporation’s refundable Part VIII tax on hand” were read as “subsidiary’s refundable Part VIII tax on hand”, (xx) “predecessor corporation’s Part VIII refund” were read as “subsidiary’s Part VIII refund”, and (xxi) “predecessor corporation’s cumulative offset account” were read as “subsidiary’s cumulative offset account”; (e.3) for the purpose of computing the parent’s investment tax credit at the end of any particular taxation year ending after the subsidiary was wound up, (i) property acquired or expenditures made by the subsidiary or an amount included in the investment tax credit of the subsidiary by virtue of paragraph (b) of the definition investment tax credit in subsection 127(9) in a taxation year (in this paragraph referred to as the “expenditure year”) shall be deemed to have been acquired, made or included, as the case may be, by the parent in its taxation year in which the expenditure year of the subsidiary ended, and (ii) there shall be added to the amounts otherwise determined for the purposes of paragraphs (f) to (k) of the definition investment tax credit in subsection 127(9) in respect of the parent for the particular year (A) the amounts that would have been determined in respect of the subsidiary for the purposes of paragraph (f) of the definition investment tax credit in subsection 127(9) for its taxation year in which it was wound up if the reference therein to “a preceding taxation year” were read as a reference to “the year or a preceding taxation year”, (B) the amounts determined in respect of the subsidiary for the purposes of paragraphs (g) to (i) and (k) of the definition investment tax credit in subsection 127(9) for its taxation year in which it was wound up, and (C) the amount determined in respect of the subsidiary for the purposes of paragraph (j) of the definition investment tax credit in subsection 127(9) for its taxation year in which it was wound up except that, for the purpose of the calculation in this clause, where control of the subsidiary has been acquired by a person or group of persons (each of whom is referred to in this clause as the “purchaser”) at any time (in this clause referred to as “that time”) before the end of the taxation year in which the subsidiary was wound up, there may be added to the amount determined under subparagraph 127(9.1)(d)(i) in respect of the subsidiary the amount, if any, by which that proportion of the amount that, but for subsections 127(3) and 127(5) and sections 126, 127.2 and 127.3, would be the parent’s tax payable under this Part for the particular year, that, (I) where the subsidiary carried on a particular business in the course of which a property was acquired, or an expenditure was made, before that time in respect of which an amount was included in computing the subsidiary’s investment tax credit for its taxation year in which it was wound up, and the parent carried on the particular business throughout the particular year, the amount, if any, by which the total of all amounts each of which is