The writer summarizes a ruling in which a group of related corporations stepped-up the cost of depreciable property through a series intra-group transfers that triggered capital gains offset by losses. The step-up of the cost of the depreciable property was limited by subparagraph 13(7)(e)(ii) to one-half of the capital gains realized on the transfers.
Dino Infanti “Step Up Capital Cost with Loss Utilization” Tax for the Owner-Manager 21:1 (January 2021)
