Subsection 55(3.02)

Administrative Policy

2024 Ruling 2023-0987001R3 - Public Spin-Off Butterfly

Background

DC2 is a public corporation wholly-owning DC1 (also a taxable Canadian corporation.) DC2 wishes to split into two publicly listed...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution successive butterflies by wholly-owned sub of Pubco and by Pubco in reliance on s. 55(3.02) 143

2023 Ruling 2022-0958241R3 - Public Spin-Off Butterfly

Background

DC, a specified corporation whose shares trade on an exchange and are not taxable Canadian property, carries on Project 1 through...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) new common shares created on s. 86 reorg then immediately converted under s. 51 back to old common shares 124
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Public Corporation - Paragraph (b) public spinco to elect effective before its shares were listed 84
Tax Topics - General Concepts - Fair Market Value - Shares FMV of listed shares based on their 5-day VWAP pre-spin-off or post spin-off 173
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(a) pre-butterfly transactions included DC acquiring shares under a plan of arrangement 71

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...

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Locations of other summaries Wordcount
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