Exceptions from Subsection 55(2) - CCH Canadian
Exceptions from Subsection 55(2) - CCH Canadian
Exceptions from Subsection 55(2) - CCH Canadian
- No tags were found...
You also want an ePaper? Increase the reach of your titles
YUMPU automatically turns print PDFs into web optimized ePapers that Google loves.
Application of Butterfly Denial Rules —Spin-off Butterfly ExampleShareholder(s)100% 100%TransfereeDCAsset 1Asset 2<strong>Exceptions</strong> to “Continuity of Interests” Rule• "Permitted exchange” - allows for transfer of shares of DC to Transferee• "Permitted redemption” - allows for disposition of shares on cross-redemption• "Permitted acquisition“ generally to facilitate sequential butterflies• Definitions found in subsection <strong>55</strong>(1)© 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 44