2015 Ruling 2015-0605901R3 F - Présomption de gain en capital -- summary under Subsection 249.1(7)

The proposed transactions contemplate (in para. 24) respecting a spin-off of real estate by Opco to newly-incorporated Realtyco that "Opco will make an advance request to the CRA to change its fiscal period end in order to close off the latter before the transfer of the depreciable assets so that Opco will claim capital cost allowance for the current fiscal period up to the amount permitted by the Act and Regulations." (Per para. 17, "the fiscal period of Realtyo will be fixed at a date which will permit the avoidance of Part IV tax circularity.")