| A divisive reorganization involves a series of transactions having as effect and purpose the division of the trading activities carried on by a single company or group of companies between two or more companies or groups of companies. This can be achieved by a sale of assets or by a transfer of shares belonging to the corporation to be divided, which would generally give rise to taxable capital gains.;The thesis analyzes the tax implications of these two approaches, with particular focus on the latter, attempting a comparative view over the UK and Canadian relevant provisions. The two substantive chapters present the UK and, respectively, Canadian rules governing the treatment of disposal of corporate assets and shares, the available reliefs from capital gains taxation, as well as the special requirements for achieving tax-free demergers. Conclusions are aimed at suggesting a more simplified approach for Canadian divisive reorganizations, with a greater degree of codification. |
