Amendment to s. 87(4) does not affect the exemption from s. 116 certificate requirement

IT-474 indicates that there is no requirement to apply for a s. 116 certificate on a statutory amalgamation involving the disposition of shares which are taxable Canadian property.  This policy still applies notwithstanding that, following on the March 2012 Budget, s. 87(4) was amended to provide that, on such an amalgamation, the shares of the amalgamated corporation are deemed to be taxable Canadian property for a period of only five years following the amalgamation.

Neal Armstrong.  Summary of 11 October 2012 T.I. 2011-0429021E5 under s. 116(1).