15 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 14, ¶1078)

A taxpayer will not be considered to have conferred a benefit pursuant to s. 85(1)(e.2) where the redemption and retraction amount of preferred shares received in exchange for rental property transferred to a corporation equals the fair market value of that property, even if the dividend rate on the shares is low in relation to current market conditions.

A taxpayer will not be considered to have conferred a benefit pursuant to s. 85(1)(e.2) where the redemption and retraction amount of preferred shares received in exchange for rental property transferred to a corporation equals the fair market value of that property, even if the dividend rate on the shares is low in relation to current market conditions.