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<strong>Exceptions</strong> to “Continuity of Asset” Rules• Dispositions in ordinary course of business– Not defined• On sequential butterflies• On an amalgamation with a related corporation• Rules do not apply to dispositions of cash or debt receivable© 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 46