Principal Issues: If a public corporation wishes to elect not to be a public corporation and, at the time of the election, its insiders do not own shares of a class that was publicly listed at any time after the corporation last became a public corporation, can it satisfy Regulation 4800(2)(a)?
Position: Yes, in the circumstances considered in this ruling.
Reasons: The circumstances of this corporation are substantially similar to those in respect of which a favorable ruling was given in Document 2015-0577141R3, following the liberal interpretation first taken in Document 2000-0004783.