Liquidity rights do not cause flow-through shares to be prescribed shares

Individuals subscribing for flow-through shares of a listed resource company will immediately donate a portion of their shares to registered charities and sell the balance.  Lining up independent "Liquidity Providers" to purchase such shares for their fair market value from the charities and directly from the individuals will not cause those shares to be prescribed shares (i.e., bad shares for flow-through purposes).

Neal Armstrong.  Summary of 2012 Ruling 2012-0466731R3 under Reg. 6202.1.