CRA noted that the taxpayer’s request for rulings had been withdrawn for the reasons noted below in the summary (the text of the letter is similar):
The purpose of the proposed series of transactions is to convert a taxable dividend that would otherwise have been paid by a corporation (Opco) out of the proceeds of sale of its business, into a proceeds of disposition the shareholders of Opco would have received from the sale, in favour of an unrelated purchaser, of the shares of a newly formed corporation that would have acquired Opco's business on a taxable basis before its shares being sold to the unrelated purchaser. The proposed series of transactions corresponds to a dividend stripping arrangement of Opco to which all the conditions under either 84(2) or the GAAR are met.