Loser Limited is a wholly owned subsidiary of Bigbucks Limited. Loser has generated the following losses which

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Loser Limited is a wholly owned subsidiary of Bigbucks Limited. Loser has generated the following losses which it has not been able to absorb in a carryover year and it is not likely to generate sufficient income to absorb them in the foreseeable future.
Loser Limited is a wholly owned subsidiary of Bigbucks Limited.

Loser's fiscal year-end is December 31.
Bigbucks has a January 31 fiscal year-end and expects to generate sufficient business income and taxable capital gains to absorb any of Loser's losses that might be made available to it. As a result Bigbucks is considering either an amalgamation [sec. 87] or a winding-up [ssec. 88(1)] effective June 30, 2008. After the reorganization, the January 31 fiscal year-end will be retained.
REQUIRED
Determine the availability to Bigbucks of the losses of its subsidiary under both alternatives being considered. Should any other factors be considered in the choice between the alternatives?

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Introduction To Federal Income Taxation In Canada

ISBN: 9781554965021

33rd Edition

Authors: Robert E. Beam, Stanley N. Laiken, James J. Barnett

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