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2017 Ruling 2016-0674681R3- Sequential Split-Up Butterfly-- summary under Paragraph 55(3.1)(a) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(a) sale of securities for cash proceeds that are reinvested, and tendering shares for shares of offeror Preliminarily to a butterfly distribution that was favourably ruled upon, DC1 sold portfolio investment units for cash, and may reinvest the proceeds in marketable securities or other investments – transactions that are represented to be independent of the butterfly transactions. ...

2006 Ruling 2006-0178571R3- Purchase of Target and Bump-- summary under Subsection 87(1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1) amalgamation with parent as survivor (forward triangular "D" merger) Parent-group losses / FIRPTA. ... Acquisition of Mergeco by Shareholder 1 and 2 group Under the second plan of arrangement: Bidco will transfer the convertible senior notes to Mergeco for cancellation The shareholder rights plan for Megeco will be cancelled The outstanding Mergeco options will be cash-surrendered to Mergeco Mergeco shares of dissenters will be transferred to Bidco for their fair value At the same time, all other Mergeco shares will be transferred to Bidco for cash consideration – except that Mergeco shares held by affiliates of Shareholder 2 will be transferred to Buyco 1 (a joint newly-formed 50/50 subsidiary of Shareholder 1 and 2) in consideration for shares of Buyco 1 All the shares of Bidco held by the Shareholder 1 and 2 groups will be transferred to Buyco 1 in consideration for shares of Buyco 1, so that Buyco 1 is owned equally by the two groups The Mergeco shares held by Buyco 1 will be transferred to Buyco 2 (an affiliate of Shareholder 1) for shares of Buyco 2 Mergeco will elect to cease to be a public corporation (and also elect under s. 256(9) in its tax return) Buyco 2 will transfer the shares of Mergeco to Bidco for shares of Bidco. ...

After the subscription by Parent for special voting shares and by each Child for common shares of a newly-incorporated TC for each Child (TC1, TC2, TC3 and or TC4), each Child will transfer under s. 85(1) to that Child’s TC a portion of the Child’s DC Common Shares (having an FMV equaling ¼ of the Transaction Assets FMV net of the Parent Note and Parent Note 2 amounts) in each case in consideration for a demand non-interest bearing promissory note of the TC having a principal amount and FMV equal to the PUC and ACB of the transferred shares and for the issuance of additional common shares of the TC. ... DC will transfer 1/4 of the Transaction Assets to each TC in consideration for the assumption of ¼ of the Parent Note and Parent Note 2 and the issuance of non-voting redeemable retractable TC preferred shares, with a joint s. 85(1) election being made. ...

2022 Ruling 2022-0937661R3 F- 104(4) and pipeline transaction-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) pipeline transaction to raise the funds for the application of the CRA s. 104(5.8) GAAR position to an inter vivos trust used to try to avoid the 21-year deemed disposition Background A family inter vivos trust for resident beneficiaries (Trust 1) had distributed its common shares of a CCPC that was an investment holding company (Holdings) on an s. 107(2) rollover basis to a corporate beneficiary (Holdco – which already held the balance of the common shares of Holdings) that was held by Father and a newly-formed inter vivos trust (Trust 2) for the same family, a corporation and a foundation (with the shares of and an advance to Holdings being the sole assets of Holdco). After a precautionary disclosure was made to CRA, it determined that GAAR applied to the rollout of the Holdings shares to Holdco, so that s. 104(5.8) should be treated as applying to the capital property of Trust 2 upon the (now imminent) occurrence of the 21 st anniversary of the formation of Trust 1 so as to result in a deemed disposition of such property pursuant to s. 104(4)(b)(ii) – and the Directorate so ruled in this ruling letter. ...

Accordingly, that portion which relates to the cancellation of the lease of the land would be deductible in accordance with the provisions set out in paragraph 20(1)(z) …." ...

See summary under s. 55(1) – distribution. ...

2012 Ruling 2012-0452291R3- XXXXXXXXXX- ATR-- summary under Share Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Share MRPS were shares A Canadian public company (Pubco) (acting through a branch in Country 1 – assumed here to be Luxembourg) will subscribe with cash for common shares and/or mandatorily redeemable preferred shares ("MRPS") of Finco. ...

See summary under s. 18(1)(a) – income producing purpose. ...

" See summary under s. 55(1) – distribution. ...

The CRA ruling letter described FA1 as a (non-resident) subject corporation rather than as a Canadian partnership, described the proportionate distribution as being deemed by s. 90(2) to be a dividend and provided a ruling that the distribution will be considered to be received as a dividend in respect of a single class of shares of capital stock of FA1 by Canco7, 8 and 9 for the purposes of s. 212.3(9)(b)(ii) – A(B). ...