2009 Ruling 2008-0304371R3 - Single-Wing Butterfly -- summary under Subsection 20(24)

In a single-wing butterfly of a company whose assets consisted of cash and cash equivalents, tenant receivables and a revenue producing rental property, the transferee corporation (B Sub Holdco) will assume various undertakings of the distributing corporation (Opco), and a joint s. 20(24) election will be made respecting the consideration paid by Opco for such assumption. Ruling: that Opco will be entitled to a s. 20(24) deduction for such payment.