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Exceptions from Subsection 55(2) - CCH Canadian

Exceptions from Subsection 55(2) - CCH Canadian

Exceptions from Subsection 55(2) - CCH Canadian

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Full Split-up Butterfly — Basic StepsTransferee ATransferee BPrefPrefCommonCommonDCPropertyS85 transferof property• DC transfers or distributes a pro rata amount of its property toeach Transferee on rollover basis• DC receives preferred shares of each Transferee© 2010 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is aSwiss entity with which the independent member firms of the KPMG network are affiliated 29

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