Natalie Worsfold

Sep 21, 2023 | mondaq.com | Peter Aprile |Natalie Worsfold |James Roberts |Jennifer S.M. Mak

Section 111 of the Income Tax Act ("ITA") allows taxpayers to carry losses back and forward to offset income in different taxation years. However, subsection 111(5) restricts non-capital loss carryovers for a corporation if there is a change in control, and the new owners do not continue the same or similar business that incurred the losses. In Deans Knight Income Corp. v.

Jun 7, 2023 | mondaq.com | Peter Aprile |Natalie Worsfold |James Roberts

Thompson Reuters considers the authors "leading tax experts and litigators". The authors agreed to grant TR partial rights to this work. This article first appeared in TR's Tax Dispute and Resolution Centre. In Brown v. Canada 2022 FCA 200, the Federal Court of Appeal restated the source-of-income test and applied the test to the taxpayer's management services activity.