Principal Issues: Minor amendments to ruling.
DC proposes to transfer the legal title to (but not beneficial ownership of) PlantC to Aco for the purposes of avoiding the land transfer tax under the Land Transfer Tax Act (Ontario). XXXXXXXXXX .
Position: 1) This is acceptable.
Reasons: 1) We have accepted this type of arrangement in previous butterflies. (See 2005-011142).
2) XXXXXXXXXX . Further, since DC, Parent and Aco will be related immediately after the reorganization, subparagraph 55(3.1)(b)(i), paragraphs 55(3.1)(b) and (c) will not be applicable.