Principal Issues: Whether the proposed split-up transactions meet legislative and administrative requirements?
Position: Transactions meet requirements.
Reasons: Consistent with law and administrative requirements.
Principal Issues: Tax implications of losses incurred as a result of a fraudulent investment scheme.
Position: Various implications discussed.
Reasons: See below.
Principal Issues: How the proposed changes to the tax on split income under section 120.4 apply in certain circumstances.
Position: General comments provided on certain issues related to the definition of excluded shares and excluded business.
Reasons: Wording of proposed legislation.