GREY:TBTEF - Post by User
Comment by
Oldfart74on Apr 08, 2017 12:08pm
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Post# 26095800
RE:RE:RE:66.7(10)
RE:RE:RE:66.7(10)Expertchoc wrote: Oldfart,- you do not agree that the ownership of the tax pool belongs to shareholders ?
- you do not agree that the original owner as defined at 66(15) act are the shareholders ?
- you do not agree that the transfer of the tax pools should be done jointly (purchaser and original owner)
- you do not you agree that the prescribed form should be completed by the original owner (shareholders), otherwise the transfer of the tax pools is not completed.
You say that the purchaser and TBE would jointly elect that all tax pools of TBE would be allocated to the purchaser. Yes, at that time the tax pools was the property of TBE in the fiscal sense before the end of the deemed year which coincides with the effective date. Immediately after the effective date, TBE (the corporation ) does not exist anymore. and the property of the tax pools becomes the property of shareholders (hence the meaning of the original owner).
A complete misreading of the situation. On the effective date, the TBE oil and gas assets were sold. TBE continues to exist.