[Verse 1] When corporations need to rearrange Section eighty-six provides exchange Shares for shares in structured dance Tax deferred if you follow the stance Control acquired, fifty percent plus Solely for shares, no cash or fuss Target assets stay in place Reorganization saves face [Chorus] Eighty-six exchange, eighty-seven merge Tax deferral when the rules converge Rollover basis, no gain today ACB transfers in the corporate way Eighty-six exchange, eighty-seven merge Keep the structure, let the benefits emerge [Verse 2] Section eighty-seven amalgamation Two corps become one in transformation Predecessor entities dissolve away New corporation starts its day Assets transfer at their cost No recapture, nothing's lost Shareholders get equivalent shares Continuity everywhere [Chorus] Eighty-six exchange, eighty-seven merge Tax deferral when the rules converge Rollover basis, no gain today ACB transfers in the corporate way Eighty-six exchange, eighty-seven merge Keep the structure, let the benefits emerge [Bridge] Boot received breaks the spell Taxable gain you'll have to tell Lesser of boot or accrued gain Tax consequences break the chain Timing matters, structure counts Every detail paramount [Verse 3] PUC calculations must align Bump and grind the bottom line Elected amounts within the range Fair market value sets the change Canadian corps, arm's length deal These conditions make it real [Chorus] Eighty-six exchange, eighty-seven merge Tax deferral when the rules converge Rollover basis, no gain today ACB transfers in the corporate way Eighty-six exchange, eighty-seven merge Keep the structure, let the benefits emerge [Outro] Corporate ladders climb and fall Reorganization conquers all Sections guide the way through Tax deferred and legal too
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