2016 Ruling 2015-0571441R3 - Dutch Cooperative - 93.2 & 95(2)(c) -- summary under Subsection 93.2(2)

Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Dutch cooperative (DC), in consideration for a credit to the membership accounts of the contributing foreign affiliates equal to the FMV of the contribution, was eligible for s. 95(2)(c) rollover treatment, CRA ruled that DC was a corporation for the purposes of the Act, and a non-resident corporation without share capital for purposes of s. 93.2 and that membership interests in DC will be deemed to be shares of a single class by s. 93.2(2).