CRA indicates that payment by a flow-through share issuer of fees for investor procurement services of an arm’s length promoter would not taint the shares as prescribed shares

CRA indicated that the payment of a fee by a flow-through share issuer to the promoter equalling the FMV of its services in finding individual purchasers for the shares and related services generally would not cause such shares to be prescribed shares.

Neal Armstrong. Summary of 9 December 2020 External T.I. 2020-0852321E5 under Reg. 6202.1(1)(b).