5 October 2012 APFF Roundtable Q. 8, 2012-0454161C6 F - Computation of CDA and Acquisition of Control -- summary under Subsection 245(4)

Where Mr. A, who owns 50% of the shares of a CCPC ("Holdco") having cash as its only asset, purchases the other 50% shareholding of Mr. B, s. 245(2) potentially may apply (Tax Interpretations Translation):

[T]he acquisition of shares of the capital stock of a corporation whose only asset is cash as in the particular situation could be part of a surplus stripping scheme in respect of which subsection 245(2) could be invoked.