David Carolin, Manu Kakkar, Boris Volfovsky, "Tax Alchemy and Paragraph 55(3.01)(g): Converting a 55(3)(b) Divisive Reorganization into a 55(3)(a) Related-Party Butterfly", Tax for the Owner-Manager, Vol. 24, No. 1, January 2024, p. 7

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.01) - Paragraph 55(3.01)(g)

Spin-off of real estate by Opco owned by 2 arm’s length shareholders does not comply with s. 55(3)(a) (p. 7)

Opco is owned on an 85-15 basis by...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a)
interposition of a Middleco in a spin-off transaction can put it back onside s. 55(3)(a)

Suppose that Opco is owned on an 85-15 basis by two arm’s-length shareholders, Aco and Bco. If Opco wishes to spin off the real property used in...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.