Following a split up butterfly and winding-up of a corporation (DC1) for which DC2 had been a holding company, DC2 is held by three corporations, TC1, TC2 and TC3. DC2 then effects s. 84(1) deemed dividends on a pro rata basis to the three TCs, which is ruled to result in a full refund of its RDTOH. There then is a single-wing split-up butterfly for the distribution of a pro rata portion of DC2’s three types of property to TC1 (including the right to the dividend refund, viewed as near-cash asset).
This single-wing butterfly concludes with the payment of a s. 84(3) deemed dividend to TC1 only (paras. 78-79). The above ruling is predicated on the taxation year of DC2 terminating before the single-wing butterfly, so that all of the dividend refund is generated before the second deemed dividend going only to TC1. The ruling letter states (para. 69.1):
Upon receipt of this Rulings letter in respect of the Proposed Transactions, if not earlier, DC2 will submit a request to the relevant Tax Services Office of the CRA to have a change of year-end. All proposed steps described in Paragraph 70 onwards [respecting the single-wing butterfly] will occur in the next taxation year of DC2.