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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Application of Butterfly Denial Rules —Spin-off Butterfly ExampleShareholder(s)100% 100%TransfereeDCAsset 1Asset 2• Paragraph <strong>55</strong>(3.1)(c) “Continuity of Assets” Rule for Transferee Corporation– Transferee is restricted <strong>from</strong> selling butterflied property• Paragraph <strong>55</strong>(3.1)(d) “Continuity of Assets” Rule for Distributing Corporation– DC is restricted <strong>from</strong> selling non-butterflied property• Rules apply if more than 10% of fair market value of property of TC or DC is sold© 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 45
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