CRA maintains its positions on s. 85.1(1) in its new Folio

CRA has rewritten IT-450R – "Share for Share Exchange" to use somewhat more pasteurized and laconic prose, but without making any substantive changes - except that a statement has been added that a right to receive shares of the purchaser in the future is treated the same as boot.  (Presumably, CRA would not intend to make an issue of this statement respecting a Plan of Arrangement which stated that every listed step shall be deemed to occur at five minute intervals.)

Positions maintained in the new Folio include:

• the s. 85.1 rollover can apply to an exchange of x% of each vendor share for a purchaser vendor share, with (100%-X%) of each share being exchanged for boot, provided that this is clearly specified in the purchaser’s offer
• up to $200 in cash can be received in lieu of fractional shares of the purchaser

Neal Armstrong. Summaries of S4-F5-C1: "Share for Share Exchange" under s. 85.1(1), s. 85.1(2.1) and ITAR 26(26).