Understanding Section 55 and Butterfly Reorganizations, 4th Edition
This book is intended to provide an understanding of butterfly reorganizations and other aspects of section 55 of the Income Tax Act (Canada), and to serve as a useful tool for tax advisers practising in the area. Since the 3rd edition of this book was published in 2010, many legislative, judicial, and interpretive developments have created the need for a fourth edition. Of special importance are the technical amendments released over the years affecting public company butterflies, the various Department of Finance comfort letters that are not yet reflected in the law, and evolving jurisprudence regarding the calculation of safe income. In addition to these and other developments, this book provides a comprehensive analysis of section 55 in its entirety and related provisions. We hope that Understanding Section 55 and Butterfly Reorganizations will prove to be a valuable resource to all income tax practitioners, from those who are novices to the intricacies of section 55, to experienced professionals.
This book addresses the state of the law and related material as of August 1st, 2020.
Rick McLean, CA, is a Partner in the tax practice with KPMG LLP in Toronto. Rick specializes in and has extensive experience in structuring mergers, acquisitions, divestitures and corporate reorganizations for both public and private companies. Rick’s key practice areas include butterfly reorganizations and post-acquisition restructurings including bump transactions. Rick is a recognized authority on Section 55. Rick is a frequent speaker on corporate reorganizations and M&A tax issues and is a lecturer for CPA Canada’s Corporate Reorganizations tax course and was a lecturer for the In-Depth Tax Course. Rick has presented at the Canadian Tax Foundation’s Annual and Ontario Conferences, the National STEP Conference, at TEI events and other conferences. Rick is a Governor of the Canadian Tax Foundation.