2000 Ruling 2000-0014443 - PUC Reduction -- summary under Subsection 84(2)

Ruling that a transfer by a Canadian public company in a taxable transaction of all the assets of a business to a Newco, followed by a distribution of Newco shares to its shareholders would give rise to a dividend only to the extent that the fair market value of the distributed shares exceeded the paid-up capital reduction associated with the distribution.