The proposed transactions contemplate (in para. 24) respecting a spin-off of real estate by Opco to newly-incorporated Realtyco that Opco (with CRA consent) will close off its year end immediately before the real estate spin-off (and immediately after the payment of a deemed dividend by it to Realtyco) in order to claim capital cost allowance for the current fiscal period. Thereafter, Realtyco will pay a deemed dividend to Opco. Per para. 17:
The fiscal period of Realtyo will be fixed at a date which will permit the avoidance of Part IV tax circularity.