CRA confirms application of s. 55(3.01)(g) safe harbour through use of a holdco

CRA has confirmed that s. 55(3.01)(g) generally will permit two unrelated individuals to spin-off real estate from a jointly owned Opco to a newly-incorporated jointly-owned Realtyco provided that they first interpose a holding company between themselves and their two companies (Opco and Realtyco).

Neal Armstrong. Summary of 14 April 2015 T.I. 2015-0570021E5 F under s. 55(3.01)(g).