2023 Ruling 2022-0958241R3 - Public Spin-Off Butterfly -- summary under Paragraph 55(3.1)(a)

CRA ruled on a butterfly spin-off by a listed Canadian corporation (DC) of its indirect interest in a foreign project to a “SpinCo” to be held by its shareholders, with most of the steps to occur pursuant to a plan of arrangement. The completed pre-butterfly transactions included DC acquiring all the shares of a Canadian corporation that were not already held by it pursuant to a plan of arrangement.