Principal Issues: Can the proposed butterfly reorganization to divide the assets of the corporate taxpayer be completed tax free?
Position: Yes.
Reasons: Meets the legislative and administrative requirements.
Principal Issues: Will the position in paragraph 23 of IT-143R3 continue to apply in light of the legislative changes and repeal of the eligible capital property system?
Reasons: 18(1)(a), 13(35), 13(36)
Principal Issues: Tax implications of losses incurred as a result of a fraudulent investment scheme.
Position: Various implications discussed.
Reasons: See below.