Administrative Policy
2021 Ruling 2020-0852951R3 - Public Spin-Off Butterfly
Background
Parent is a public corporation with two classes of outstanding shares and has a specified shareholder (a CCPC) which holds its Parent...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) | stock options replaced by stock options with lower exercise price on shares of shrunken post-spin-off corp | 131 |
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Public Corporation | election made for Newco that is spun-off by Pubco | 130 |
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(1) | 85.1 applicable on exchange by Pubco shareholders for shares of spin-off sub | 142 |