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...
Locations of other summaries | Wordcount | |
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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...
Locations of other summaries | Wordcount | |
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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...
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 |