2016 Ruling 2015-0571441R3 - Dutch Cooperative - 93.2 & 95(2)(c) -- summary under Subsection 85.1(3)

Ruling respecting the combined operation of s. 95(2)(c) (similar in this regard to s. 85.1(3)) and s. 93.2) on a joint contribution by the three foreign affiliate shareholders of a foreign affiliate of their respective shareholdings to a Dutch co-operative (with membership interests rather than share capital) in consideration for credits to their respective membership interest accounts.