Subsection 55(3.2)

Paragraph 55(3.2)(d)

Administrative Policy

29 October 2013 External T.I. 2013-0489771E5 F - Internal Reorganization - 55(3)(a)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) estate distribution of corporation followed by transfer of assets from related corporation could be part of same series 160
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(v) relief under s. s. 256(7)(a)(i)(C) or (D) is relevant to s. 55(3.1)(b)(ii), but not to ss. 55(3)(a)(i) to (v) 213

Paragraph 55(3.2)(h)

Administrative Policy

2013 Ruling 2012-0459781R3 - 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 butterfly reversing previous amalgamation and using 4-party exchange 1042
Tax Topics - Income Tax Act - Section 212.1 - Subsection 212.1(1.1) - Paragraph 212.1(1.1)(b) PUC grind where shares issued in 4-party exchange 212

Articles

Rick McLean, Canadian Tax Highlights, Vol. 22, No. 5, May 2014, p. 6.

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Janice G. Russell, "Cross-Border Butterfly Ruling", (2011) vol. 19, no. 1 Canadian Tax Highlights, 8-9:

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Kila, Williamson, "Section 55 Case Study: Impact of Proposed Paragraph 55(3.2)(h) on a Cross-Border Spin-off Transaction", Corporate Structures and Groups, Vol. IV, No. 2, 1997, p. 203.

Marc N. Ton-That, Serge Bilodeau, "Breaking Up Is Hard To Do", 96 Conference Report (CTF), p.11:51

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