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More specifically: Aco establishes a new sister to Bco (Newco) to which Aco does an s. 85(1) drop-down of preferred shares of Bco having a fair market value equaling that of the trademarks; Bco spins-off the trademarks to Newco on a partial rollover basis in consideration for prefs of Newco, thereby using Bco’s net capital losses to effect a ½ step-up of the UCC of the trademarks under s. 13(7)(e)(ii) – and with Newco licensing the trademarks back to Bco for royalties; The prefs in 1 and 2 above are cross-redeemed (with reliance on the s. 55(3)(a) exception to s. 55(2)); Newco is wound-up under s. 88(1); Aco does an s. 85(1) drop-down of the trademarks back to Bco, but choosing an elected amount so as to uses up its net capital losses and to effect a further ½ step-up of the trademarks' UCC under s. 13(7)(e)(ii). ...

The estate will transfer all of its Class A shares to a newly formed corporation (Newco) in consideration for Note 2 and one Class A share of Newco, electing under s. 85(1). ...

Each of Leg1 and Leg2 will transfer all of their shares of Holdco to Newco in consideration for a note (Note 1 or Note 2) equalling the aggregate ACB of the transferred shares and for Class E non-voting non-cumulative redeemable retractable Class C shares of Newco, electing under s. 85(1). ...

A conventional pipeline was to be implemented under which AE Trust transferred its common shares of Aco and Bco on a s. 85(1) rollover basis to a “Newco” in consideration for two notes of Newco and nominal-value preferred shares with a price adjustment clause and, after the passage of (presumably) one year, Newco would be amalgamated with Aco and Bco, and the notes would then be gradually repaid. ...

After preliminary transactions to distribute capital dividends and eligible dividends from the companies, the trusts were then to engage in pipeline transactions in which the Aco and Bco shares were to be transferred to a ULC Newco on a s. 85(1) rollover basis in consideration for notes and nominal value preferred shares with redemption values subject to a price adjustment clause, and then convert those notes to high-PUC shares of the ULC – and only after a number of years, might ULC be amalgamated with Aco and Bco (which would have been continued to the same jurisdiction as Aco and Bco). ...

Proposed transactions The Estate will transfer its Class D shares to a corporation newly incorporated by it (Newco) in consideration for voting and participating shares of Newco, electing under s. 85(1). ...

Following the death of Mother, her estate and Trust were to engage in a pipeline transaction under which: The estate and Trust transfer their Aco shares under s. 85(1) to a Newco of Trust in consideration for Newco preferred shares. ...

On the day for settlement of a redemption/repurchase transaction, there will be, in quick succession, a transfer by the registered plan of its Trust units to Buyco, a redemption of such units in the hands of Buyco for USco shares, and the repurchase of such shares by USco for consideration consisting of it directing that funds in a Canadian bank deposit previously held for it will thereupon be held for the benefit of the plan, thereby satisfying its obligation to pay the share repurchase price to Buyco, and Buyco’s obligation to pay the purchase price for the Trust units. ...

Parent Amalco engaged in various transactions to increase the PUC of its shares of a Canadian subsidiary (“Corporation”) to their adjusted cost base or ACB including transferring a Canadian royalty interest (providing a net smelter return) and shares of four subsidiaries (having, depending on the subsidiary, an FMV higher or lower than their PUC, before giving effect to full s. 111(4)(e) step-ups of the appreciated shares) in consideration for preferred shares with a PUC equal to the s. 85(1) elected amount. ...

One of the preliminary transactions on which CRA did not rule was the sale by Partnerships C and D of Canadian resource properties (CRP) to ParentCo for cash consideration so as to reduce the balances in their successor CCEE and CCOGPE, thereby minimizing the risk of s. 66.7(16) applying as a consequence of CRP transfers to ParentCo on their windings-up. ...