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ARTICLE · 05 MARCH 2010

Federal Budget 2010 – Income Tax Measures

On March 4, 2010, the federal government tabled its Budget. This bulletin summarizes the principal income tax measures affecting businesses contained in the Budget.

CanadaTax

Originally published March 2010

On March 4, 2010, the federal government tabled its Budget. This bulletin summarizes the principal income tax measures affecting businesses contained in the Budget.

A. TAX RATES

Budget 2010 contains no changes to corporate and personal tax rates.

B. DOMESTIC CORPORATE TAXATION

SIFT Conversion and Loss Trading

Where control of a corporation is acquired, tax losses realized by the corporation arising in a pre-acquisition of control period may generally not be used to reduce tax payable in respect of a post-acquisition of control period. A special rule in the Income Tax Act (the "Act") generally deems an acquisition of control of a corporation (and its subsidiaries) to occur where the corporation issues shares in consideration for the shares of a target corporation in a "reverse takeover", e.g. where the shareholders of the target collectively receive shares of the acquirer representing, in the aggregate, control of the

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