DeeThree Exploration effects a butterfly spin-off of Boulder Energy

DeeThree, an Alberta TSX-listed oil and gas company, has completed a butterfly spin-off of Boulder Energy, which holds what was a major development property of DeeThree. In contrast to the recent FirstService/Collier butterfly spin-off, no tax ruling was sought, no indemnities were given respecting post-Arrangement actions that might cause the butterfly to be taxable and no tax risks were disclosed.

Similarly to FirstService/Collier, the U.S. tax disclosure contemplates that the reorganization will be treated as a qualifying Code s. 355 distribution on the basis of the form of the transactions being disregarded.

Neal Armstrong. Summary of DeeThree Circular under Spin-Offs & Distributions – Butterfly spin-offs.