81 C.R. - Q.6

Notwithstanding Rapistan, know-how that is of a capital nature is eligible capital property.

Where consequences of receiving a s. 84(1) dividend as a result of the paid-up capital of shares issued on a s. 85(1) roll exceeding the fair market value of the property transferred are "extremely harsh", RCT is prepared to consider whether administrative relief is warranted.

S.85(1)(e.2) will not be applied to transactions which comply with s. 55(3)(b).

Where the transfer of assets under section 85 followed by a sale of shares is simply an attempt to convert what would otherwise be an income gain to a capital gain, the profit on the sale of the shares will be considered to be "income."