CRA rules that a simultaneous consolidation of 7 identical series of common shares into 1 series, and a stock split, did not effect a disposition
With a view to going public, a closely-held US corporation, whose issued and outstanding shares (which were taxable Canadian property and held by Canadian and US-resident corporate shareholders) consisted of seven series of common shares with identical attributes, proposed to amend its articles of incorporation so as to reclassify all the common shares into one series and to simultaneously effect a stock split. CRA ruled that this did not entail a disposition of the shares, so that no s. 116 certificate was required
Neal Armstrong. Summary of 2020 Ruling 2019-0799981R3 under s. 248(1) – disposition.