2020 Ruling 2020-0854091R3 - Safe Income and Section 47 -- summary under Subsection 85(1)

The proposed transactions included Parent exchanging all its Common Shares of Subsidiary on a s. 85(1) rollover basis for non-voting redeemable retractable non-cumulative preferred shares of Subsidiary (the “New Pref”) and Class A Common Shares with attributes identical to those of the Common Shares other than a different period of notice for shareholders’ meetings and being convertible into Common Shares on a one-for-one basis. The PUC of the Common Shares is allocated to the new shares on a relative FMV basis. The New Prefs have a cost equaling their redemption amount. Rulings were only requested on safe income matters.