2000 Ruling 2000-0010723 - STOCK BONUS PLAN -- summary under Subsection 245(4)

A corporation ("TC") previously transferred a property to another corporation ("DC") and received non-voting preferred shares of DC as consideration. In connection with a butterfly reorganization of DC, the addition of voting rights to such preferred shares in order that DC would be connected with TC for Part IV tax purposes would not result in the application of s. 245(2) given that DC would have been connected from the outset if the preferred shares originally issued had been voting.