in a single-wing butterfly in which assets are distributed to a holding company for one of the two brothers which control the corporation, the business assets of the distributing corporation which are transferred on a rollover basis to "Newco" include depreciable property. For purposes of determining the elected amount:
the reference to the "undepreciated capital cost to the taxpayer of all property of that class immediately before the disposition" found in subparagraph 85(1)(e)(i) will be interpreted to mean that proportion of the undepreciated capital cost to the taxpayer of all the property of that class that the FMV of the assets that are transferred immediately before the disposition is of the FMV of all property of that class immediately before the disposition.