Full text
Subject to subsection (5.5), if at any time a taxpayer is subject to a loss restriction event,
Subject to subsection (5.5), if at any time a taxpayer is subject to a loss restriction event,
Subject to subsection (5.5), if at any time a taxpayer is subject to a loss restriction event,
Where, at any time, control of a corporation (other than a corporation that at that time became or ceased to be exempt from tax under this Part on its taxable income) has been acquired by a person or group of persons, no amount may be deducted under paragraph 20(1)(l) in computing the corporation’s income for its taxation year ending immediately before that time and each amount that is the greatest amount that would, but for this subsection and subsection 26(2) of this Act and subsection 33(1) of the Income Tax Act, chapter 148 of the Revised Statutes of Canada, 1952, have been deductible under paragraph 20(1)(l) in respect of a debt owing to the corporation immediately before that time shall be deemed to be a separate debt and shall, notwithstanding any other provision of this Act, be deducted as a bad debt under paragraph 20(1)(p) in computing the corporation’s income for the year and the amount by which the debt exceeds that separate debt shall be deemed to be a separate debt incurred at the same time and under the same circumstances as the debt was incurred.