The purpose of a spinoff butterfly is to move some property of a distributing corporation to one or more newly incorporated transferee corporations having the same shareholders in the same proportions as the distributing corporation. Although it is generally understood that such transactions are acceptable tax planning, paragraph 55(3.1)(a) raises questions. Published in vol. 3, no. 4 of Canadian Tax Focus.
Article
Spinoff Butterflies in Trouble?
2013
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