Words and Phrases - "gross FMV butterfly"

a
88
b
44
c
80
d
54
e
38
f
31
g
20
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
77
s
90
t
47
u
16
v
9
w
23
y
2

2021 Ruling 2019-0821121R3 - Multi-wing split-up gross asset butterfly

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution
pre-butterfly amalgamation to create business property and post-butterfly amalgamation to minimize Pt. IV tax/ gross FMV multi-wing butterfly

Background

Parentco is equally owned by three holding companies (Holdcos 1, 2, and 3) for three siblings holding preferred shares and their...

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Words and Phrases
gross FMV butterfly
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 representations re properties being held in co-ownership rather than partnership 220
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) purpose of amalgamation was to create a short taxation year 29