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Article Summary
Elizabeth Boyd, Jeremy J. Herbert, "Trusts Holding Shares For Employees", draft 2023 CTF Annual Conference paper -- summary under Subsection 7(2)
The transfer of shares from treasury to the 7(2) Trust could be completed after a corporate freeze transaction or during the start up phase of operations, so that the shares acquired by the 7(2) Trust (through a fair market value share subscription, or through a contribution of the shares by the employer corporation for no consideration) would have a nominal value – so that the employment benefit to the employees also could be nominal. ...
Article Summary
Christian Desjardins, Nik Diksic, "Cross-Border Butterflies in the Context of Public Spin-Off Transactions", 2015 CTF Annual Conference paper -- summary under Paragraph 55(3.1)(b)
This … may not have arisen if, for example, Foreign Spinco held the DC shares through a single purpose foreign holding company. ...