2 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 11, ¶1083)

A butterfly reorganization involving the distribution of land inventory which is achieved on a rollover basis under ss.97(2) and 90(3) through the use of partnerships could entail an abuse through circumvention of the provisions of s. 85 which deny the benefits of the rollover to real estate inventory.

A butterfly reorganization involving the distribution of land inventory achieved on a rollover basis under ss.97(2) and 90(3) through the use of partnerships could entail an abuse through circumvention of the provisions of s. 85, which deny the benefits of the rollover to real estate inventory.