2015 Ruling 2015-0605901R3 F - Présomption de gain en capital -- summary under Subparagraph 55(3)(a)(ii)

CRA ruled (as well as providing an opinion under the July 31, 2015 draft amendments) on the non-application of s. 55(2)(a) to transactions, which start with individuals (who apparently are unrelated for s. 55 purposes) holding their shares of Opco through their respective holding companies, then entail the holding companies transferring their Opco shares to a common holding company (Holdco) and, following a spin-off of Opco real estate to a new subsidiary of Holdco (Realtyco), Holdco ends up holding each of Opco and Realtyco as standalone subsidiaries. CRA also specifically ruled that the transactions would be deemed by s. 55(3.01)(g) to not be described in s. 55(3)(a)(ii).