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You are allowed a notional deduction for a previous year's loss only if the CFC was a CFC when the loss was incurred and at the end of each period until the loss is claimed.
In working out the previous years' losses of the CFC, you must assume that you were always an attributable taxpayer who was required to work out attributable income. Therefore, it is possible to carry forward a loss from a period when you were not an attributable taxpayer.
You cannot take into account any loss incurred in a statutory accounting period that commenced before 1 July 1983.
Last modified: 05 Dec 2006QC 17522