THE CRA WAS RIGHT: SECTION 87 IS NOT REDUNDANT.

The article discusses the court case CGU Holdings Canada Ltd. v. The Queen which challenges section 87 amalgamation of the Income Tax Act in Canada. The CGU filed the case after the Canada Revenue Agency (CRA) denied a refund on the basis that no election was permitted and that in any case CGU had no refundable tax account. CGU argued that under corporate law, predecessors that amalgate with each other do not cease to exist and therefore entitled to make an election.