Foreign Spin-offs – S.86.1 Election

February 27, 2026

Canadian investors (investor) often own foreign corporation shares in their portfolios. Where a foreign corporation (original corporation) distributes shares of another corporation (spin-off corporation) in kind due to a corporate reorganization, the transaction is commonly referred to as a foreign spin-off. Post reorganization, the investor now owns shares of the original and spin-off corporations in their portfolio.
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