Christian Desjardins, Nik Diksic, "Cross-Border Butterflies in the Context of Public Spin-Off Transactions", 2015 CTF Annual Conference paper

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(b)

History of s. 55(3.1)(b) (pp. 29:3)

[The main purpose of the original version of subsection 55(3.1) was to prevent…using the butterfly exemption...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
reorganization
Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution

Net cash/investment property transferred driven by relative FMV of spun-off business assets (p.29:20)

[T]he CRA requires that the redemption...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.