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Ruling
1999 Ruling 9905033 - BUTTERFLY REORGANIZATION
XXXXXXXXXX owns XXXXXXXXXX units of XXXXXXXXXX, representing approximately XXXXXXXXXX % of the XXXXXXXXXX issued and outstanding units of XXXXXXXXXX, In XXXXXXXXXX announced its intention to commence normal course purchases of units of XXXXXXXXXX through the facilities of XXXXXXXXXX. ...
Ruling
1999 Ruling 9902483 - BUTTERFLY RULING
The share capital of each new corporation will consist of: (a) a class of common shares; and (b) a class of special shares designated as Class A special shares with the following share attributes: (i) voting; (ii) redeemable and retractable at a redemption amount ("Redemption Amount") of $XXXXXXXXXX per share; (iii)for the purpose of subsection 191(4) of the Act, the terms and conditions of the Class A special shares to be issued as described in paragraph 15 below will, at the time of their issue, specify $XXXXXXXXXX per share as the amount for which the share is to be redeemed, acquired or cancelled which amount will be equal to the fair market value of the property received by the particular new corporation as consideration for such share; (iv) entitled to an annual non-cumulative dividend, not to exceed xxxxxxxxxx % per annum of their Redemption Amount, to be paid at the discretion of the directors of the particular new corporation; and (v) the stated capital of these special shares will be determined on the date of issuance. 6. ...
Ruling
2018 Ruling 2018-0756881R3 - Net Asset Butterfly - Farm
As at XXXXXXXXXX, the following Shareholder Advances and Shareholder Loans were outstanding – a positive amount represents an amount due from the corporation to the shareholder: Mr. ...
Ruling
2018 Ruling 2018-0749491R3 - 55(3)(a) Reorganization
On the Transaction Date, Child 1, Child 2, Child 3, and Child 4 will each transfer to TC1, TC2, TC3 and TC4, as the case may be, such number of DC Common Shares having an aggregate FMV equal to one-quarter of the aggregate FMV of the Transaction Assets less one-quarter of the aggregate amount outstanding on the Parent Note and Parent Note 2 (in each case, the “ TC1 Transferred Shares”, “TC2 Transferred Shares”, “TC3 Transferred Shares” and “TC4 Transferred Shares”) in the manner described in Paragraphs 20 to 24. 20. ...
Ruling
2022 Ruling 2021-0886471R3 - Split Up Butterfly
XXXXXXXXXX 2021-088647 XXXXXXXXXX, 2022 Object: Income Tax Ruling – Butterfly Transactions XXXXXXXXXX Dear XXXXXXXXXX, We are writing in response to your request for an advance income tax ruling (“Ruling Request”) dated XXXXXXXXXX behalf of the above-noted taxpayers (the “Taxpayers”). ...
Ruling
2006 Ruling 2006-0191591R3 - Sequential Butterfly Reorganization
The DC Special Shares will have the following terms and conditions: (a) each DC Special Share will be redeemable, subject to applicable law, at any time at the option of DC at a redemption amount equal to the amount obtained by the formula (A/B x C)/D, where A equals the net FMV of the DC Real Property and the Subco Common Shares immediately before the distribution described in Paragraph 41; B equals the net FMV of all of the business property of DC immediately before the distribution described in Paragraph 41; C equals the aggregate FMV of all DC's issued and outstanding shares determined immediately before the DC share exchanges described in Paragraph 33; and D equals the number of DC Special Shares issued on the DC share exchanges described in Paragraph 33, plus any declared but unpaid dividends; (b) each DC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described in (a) above; (c) the holder of each DC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of DC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of DC if the resulting realizable value of the net assets of DC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the DC Special Shares then outstanding; (e) the holder of each DC Special Share will be entitled, upon the liquidation, dissolution or winding-up of DC, to a payment in priority to all other classes of shares of DC ranking junior to the DC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each DC Special Share will not be entitled to vote at meetings of shareholders of DC. ... The TC Special Shares will have the following terms and conditions: (a) each TC Special Share will be redeemable, subject to applicable law, at any time at the option of TC at a redemption amount equal to the aggregate FMV of the consideration for which such share was issued divided by the total number of issued TC Special Shares (plus any declared but unpaid dividends); (b) each TC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each TC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of TC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of TC if the resulting realizable value of the net assets of TC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the TC Special Shares then outstanding; (e) the holder of each TC Special Share will be entitled, upon the liquidation, dissolution or winding-up of TC, to a payment in priority to all other classes of shares of TC ranking junior to the TC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each TC Special Share will not be entitled to vote at meetings of shareholders of TC. 36. ...
Ruling
2005 Ruling 2005-0111421R3 - Sequential Spin-off Butterfly Reorganization
The DC Sub Special Shares will have the following terms and conditions: (a) each DC Sub Special Share will be redeemable, subject to applicable law, at any time at the option of DC Sub at a redemption amount equal to the amount obtained by the formula (A/B x C), where A equals the net FMV of the DC Sub Spin-Off Property immediately before the distribution described in Paragraph 23; B equals the net FMV of all of the business property of DC Sub immediately before the distribution described in Paragraph 23; and C equals the aggregate FMV of a DC Sub Common Share determined immediately before the DC Sub share exchanges described in Paragraph 16; plus any declared but unpaid dividends; (b) each DC Sub Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each DC Sub Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of DC Sub; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of DC Sub if the resulting realizable value of the net assets of DC Sub after payment of the dividends would be less than the aggregate of the redemption amounts of all of the DC Sub Special Shares then outstanding; (e) the holder of each DC Sub Special Share will be entitled, upon the liquidation, dissolution or winding-up of DC Sub, to a payment in priority to all other classes of shares of DC Sub ranking junior to the DC Sub Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each DC Sub Special Share will not be entitled to vote at meetings of shareholders of DC Sub. ... The TC Special Shares will have the following terms and conditions: (a) each TC Special Share will be redeemable, subject to applicable law, at any time at the option of TC at a redemption amount equal to the aggregate FMV of the consideration for which such share was issued divided by the total number of issued TC Special Shares (plus any declared but unpaid dividends); (b) each TC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each TC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of TC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of TC if the resulting realizable value of the net assets of TC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the TC Special Shares then outstanding; (e) the holder of each TC Special Share will be entitled, upon the liquidation, dissolution or winding-up of TC, to a payment in priority to all other classes of shares of TC ranking junior to the TC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each TC Special Share will not be entitled to vote at meetings of shareholders of TC. 36. ...
Ruling
2000 Ruling 1999-0011213 - public corporation spin-off
In all cases, the exercise price of each XXXXXXXXXX/Fco Option outstanding under the XXXXXXXXXX/Fco Plan is not less than XXXXXXXXXX % of the fair market value of the shares for which such option was exercisable at the time the option was granted. ... XXXXXXXXXX/Aco will own approximately XXXXXXXXXX % of the issued and outstanding XXXXXXXXXX/Ico Common Shares. ...
Ruling
2022 Ruling 2020-0873371R3 - Multi-wing split-up net asset butterfly
LP4 owns an interest in joint ventures, mortgages receivable and land inventory which include the following: • XXXXXXXXXX. ... The issued and outstanding share capital of Holdco 2 is held as follows: Shareholder Class of Shares Number of Shares Owned PUC = ACB Siblingco 2 Class A common XXXXXXXXXX XXXXXXXXXX Class A preference XXXXXXXXXX XXXXXXXXXX Class C preference XXXXXXXXXX XXXXXXXXXX Class D preference XXXXXXXXXX XXXXXXXXXX Class F-1 preference XXXXXXXXXX XXXXXXXXXX Class G preference XXXXXXXXXX XXXXXXXXXX Siblingco 3 Class A common XXXXXXXXXX XXXXXXXXXX Class A preference XXXXXXXXXX XXXXXXXXXX Class C preference XXXXXXXXXX XXXXXXXXXX Class D preference XXXXXXXXXX XXXXXXXXXX Class F-2 preference XXXXXXXXXX XXXXXXXXXX Class G preference XXXXXXXXXX XXXXXXXXXX Indirect Holdco 6 Sub Class E preference XXXXXXXXXX XXXXXXXXXX The Class A common shares of Holdco 2 are voting (XXXXXXXXXX vote per share), while all of the preference shares are non-voting and non-convertible. 17. ...
Ruling
2007 Ruling 2006-0215751R3 - Cross-border butterfly
The aggregate FMV, immediately before the transfer of the Newco Common Shares by Canco to Tco described in Paragraph 44, of the Foreign Spinco membership interests owned by Foreign Pubco will be equal to or approximate the amount determined by the formula, on the assumption that Foreign Pubco is the participant, Canco is the distributing corporation and Foreign Spinco is the acquiror, (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). 33. ...