Principal Issues: In a given situation, where a taxpayer transferred public corporation shares to his holding corporation, established the value of the shares without using the CRA's position on the valuation of shares in IC 89-3, provided this value to the professional who prepared the rollover form on his behalf, there is a significant difference between the value attributed to the shares by the taxpayer and their FMV, and, the normal reassessment period applicable to the taxpayer for the year of the share transfer has expired, whether (1) the CRA could reassess the year of the disposition of the shares pursuant to subparagraph 152(4)(a)(i)? and (2) a penalty under subsection 163.2 could apply to the preparer of the taxpayer's rollover form and/or tax return for that year?
Position: (1) Yes. (2) Yes.
Reasons: General comments.