Shulkov - Tax Court of Canada accepts valuation of shares using 5-day VWAP

After surviving a 17-day trial focused on whether s. 160 applied to the transfer of substantial blocks of shares of penny stock by an executive of the company in question to his common law wife, D'Arcy J. accepted the valuation of the transferred shares in the Crown's valuation report - which valued the shares at each transfer time at their 5-day VWAP, and applied a discount ranging from 1.3% to 3.6% to reflect that it would take up to 44 days to sell-off each transferred block.

Neal Armstrong.  Summary of Shulkov v. The Queen, 2012 TCC 247 under General Concepts - Fair Market Value - Shares.