Subsection 55(3.1)

Paragraph 55(3.1)(a)

Administrative Policy

2017 Ruling 2016-0674681R3 - Sequential Split-Up Butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution sequential split-up butterfly with 1% tolerance, triggering of capital gains to generate CDA and RDTOH, and year end change to accommodate RDTOH division 656
Tax Topics - Income Tax Act - Section 129 - Subsection 129(1) capital gain deliberately triggered to generate CDA and RDTOH addition and year end change granted to isolate dividend refund 499
Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(7) CRA accommodates year end change so that dividend refund of full RDTOH balance is generated in Year 1 202

2014 Ruling 2014-0528291R3 - Butterfly Reorganization

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2013 Ruling 2013-0491651R3 - Cross-Border Butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution cross-border b/f with 3-party exchange, cash-out of ineligible shareholders, proportionate allocation of foreign spinco debt, pension liability classification, prelim non-series dividend 945
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(b) - Subparagraph 55(3.1)(b)(i) cross-border b/f with 3-party exchange, pro rata application of upper tier debt, cash-out of ineligible shareholders 457
Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) exchange for substantively identical common shares 114

7 October 2011 Roundtable, 2011-0399401C6 - Butterfly, life insurance policies, grandfathering

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2000 Ruling 1999-001072 -

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Other 33

Income Tax Technical News, No. 16, 18 December 1998

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1996 Corporate Management Tax Conference Roundtable Q. 18, 5-962079 -

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Income Tax Regulation News, Release No. 3, 30 January 1995 under "Butterfly Reorganizations"

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Articles

Marshall Haughey, "Spinoff Butterflies in Trouble?", Canadian Tax Focus, Volume 3, No. 4, November 2013, p. 3.

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Firoz Ahmed, "Subsection 55(3) Update", Canadian Current Tax, Vol. 15, No. 8, May 2005, p. 69:

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Vance Sider, "Section 55: Administrative Developments", 1995 Corporate Management Tax Conference Report, c. 8.

Paragraph 55(3.1)(b)

Administrative Policy

22 January 2016 External T.I. 2015-0617601E5 F - Pipeline followed by butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) pipeline transaction can be coupled with a butterfly split-up 454

Articles

Christian Desjardins, Nik Diksic, "Cross-Border Butterflies in the Context of Public Spin-Off Transactions", 2015 CTF Annual Conference paper

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Words and Phrases
reorganization

Subparagraph 55(3.1)(b)(i)

Administrative Policy

2014 Ruling 2014-0530961R3 - Cross-Border Butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution U.S./Cda b/f including conversion of Foreign Spinco and TC from fiscally disregarded to regarded for Code purposes/2-stage transfer to TC of cash assets/post-b/f dividend by DC/s. 86.1 treatment/proportionate allocation of Foreign Spinco debt 1382
Tax Topics - Income Tax Act - Section 86.1 - Subsection 86.1(2) spin-off by U.S. pubco of U.S. spinco after Canadian butterfly 109

2013 Ruling 2013-0491651R3 - Cross-Border Butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution cross-border b/f with 3-party exchange, cash-out of ineligible shareholders, proportionate allocation of foreign spinco debt, pension liability classification, prelim non-series dividend 945
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(a) preliminary LP acquisition, cross-border debt repayments and dividend: not part of series 212
Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) exchange for substantively identical common shares 114

2012 Ruling 2011-0425441R3 - Cross Border Butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution cross-border b/f with 3-party exchange to address s. 55(3.2)(h)/indemnity neutralizes liability assumption/Newco 3 is implicit DC 329

2012 Ruling 2012-0439381R3 - Cross-border spin-off butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution cross-border b/f as part of foreign spin-off including (U.K.?) demergers 750

2012 Ruling 2011-0431101R3 - Cross-border spin-off butterfly

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Paragraph 55(3.1)(c)

Administrative Policy

29 November 2016 CTF Roundtable Q. 2, 2016-0669651C6 - Computation of safe income

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2010 Ruling 2010-0357061R3 - Split-up butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 co-ownership not a partnership 225

3 October 2011 External T.I. 2011-0421341E5 - Paragraphs 55(3.1)(c) or (d)

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x1995 Tax Executives Institute Round Table, Q. 2, File No. 951074

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31 July 1995 T.I. 951844 (C.T.O. "50731")

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