The respondent correctly states that when the scope and extent of a deeming provision is ambiguous, a narrow construction should be preferred (The Queen v. La Survivance, 2006 FCA 129). However, when a deeming provision is clear and unambiguous, effect must be given to it. Here, based on both a plain and a contextual reading of paragraph 87(7)(d), an amalgamated corporation stands in the shoes of its predecessor insofar as previously incurred debts are concerned as of the time when they were incurred.
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