David Carolin, Manu Kakkar, "Freezes and Butterflies: Who Said Freezes are Easy?", Tax for the Owner-Manager,” Vol. 25, No. 2, April 2025, p. 9

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(ii)

Inability to effect post-spin-off freeze in favour of TC family trust if any unrelated beneficiaries (p. 9)

  • Dad and Son, who are the 50-50...

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Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(b) - Subparagraph 55(3.1)(b)(i) - Clause 55(3.1)(b)(i)(C)

Inapplicability of s. 55(3.1)(b)(i) exception if post-butterfly freeze by TC entails only a subscription by trust for common shares (pp....

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