2015 Ruling 2015-0564981R3 - "cross-statute" amalgamation -- summary under Subsection 87(1)

As part of a Plan of Arrangement for the spin-off by an agricultural cooperative corporation (“ACC”) of one of its two businesses under a Plan of Arrangement, the ACC will be amalgamated with a subsidiary corporation (“Subco”) which was incorporated under a different statute, with Amalco being considered to be formed under that same other statute. CRA ruled that this amalgamation will be considered to be a s. 87(1) amalgamation.