Corporate Groups and the Degrouping Rules – Comparing Capital Gains and IP Groups

 Corporate Groups, Corporate Tax, IP Tax  Comments Off on Corporate Groups and the Degrouping Rules – Comparing Capital Gains and IP Groups
Apr 222013
 

We have seen in previous articles how the degrouping rules operate to prevent the use of a corporate vehicle to shelter taxable gains. There are two sets of rules, one for capital assets and the other for intangibles (“IP”). In this article we shall look at how these rules differ, giving a specific example involving a business sale.

(This article can be downloaded in pdf format at Academia.edu.)

Continue reading »