CRA finds that a share exchange is not a disposition

CRA considers that the exchange of shares held in street name in a Canadian account and listed on the TSX for identical shares listed on the NYSE and held in an American account, through some sort of off-market transaction which is internal to the investor's brokers, does not constitute a disposition of the shares.  Although this interpretation might seem surprising, it is not far removed from the well-accepted view that the existence of a shareholding as property does not depend on it being evidenced by share certificate(s).

Neal Armstrong.  Summary of 5 October 2012 APFF Round Table Q. 22, 2012-0455431C6 F under s. 248(1) - disposition.