Mark McLaughlin outlines a lesser-known tax relief when an unincorporated business is transferred to a limited company upon incorporation.
When an unincorporated business is transferred to a company upon incorporation, this results in a cessation by the business owner (i.e., the sole trader, or partnership).
If a trade was loss-making immediately prior to incorporation, the normal rules allowing for trading losses to be carried forward against future profits of the same trade (ITA 2007, s 83) cease to apply, because the trade is no longer carried on by the sole trader or partnership (i.e., the company is a separate legal entity). Hence, unless the loss can be used in
