2007 Ruling 2006-0215751R3 - Cross-border butterfly -- summary under Distribution

In a net equity butterfly, after the current liabilities are allocated to cash and near-cash property, "any remaining net FMV of any accounts receivable , trade receivables, inventories and prepaid expenses of Canco will be reclassified as business property and excluded from the cash or near-cash property, to the extent that such property will be collected, sold or used in the ordinary course of the business to which such property relates." (para 35(b)(ii))

Business property did not include (and investment property included) assets any income from which would be income from a specified investment business. (para. 33)

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