Section 271 — Excise Tax Act: Amalgamations

Where two or more corporations (each of which is referred to in this section as a “predecessor”) are merged or amalgamated to form one corporation (in this section referred to as the “new corporation”), otherwise than as the result of the acquisition of property of one corporation by another corporation pursuant to the purchase of the property by the other corporation or as the result of the distribution of the property to the other corporation on the winding-up of the corporation, except as otherwise provided in this Part, the new corporation shall, for the purposes of this Part, be deemed to be a separate person from each of the predecessors; for the purposes of applying the provisions of this Part in respect of property or a service acquired, imported or brought into a participating province by a predecessor, for the purposes of sections 231 and 249, and for prescribed purposes, the new corporation shall be deemed to be the same corporation as, and a continuation of, each predecessor; and for the purposes of this Part, the transfer of any property by a predecessor to the new corporation as a consequence of the merger or amalgamation shall be deemed not to be a supply.