31 August 1992 Memorandum (Tax Window, No. 24, p. 3, ¶2191)

The use of s. 55(3)(b) to effect a transfer of assets deriving their value principally from real estate in the guise of a treaty-protected share sale was a misuse of the Act within the meaning of s. 245(4).

The use of s. 55(3)(b) to effect a transfer of assets deriving their value principally from real estate in the guise of a treaty-protected share sale was a misuse of the Act within the meaning of s. 245(4).