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S4-F7-C1- Amalgamations of Canadian Corporations-- summary under Subsection 87(4) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 1.69 For greater certainty, the rollover under subsection 87(4) is not available to shareholders whose shares of a predecessor corporation are converted into shares of the amalgamated corporation on a non-qualifying amalgamation…. 1.70 The rollover provided for in subsection 87(4) will not be denied solely because a shareholder of a predecessor corporation receives cash or other consideration in lieu of fractional shares of the new corporation. … However, this choice is not available if the total amount or value of any non-share consideration received exceeds $200. 1.72 The allocation of cost described in [s. 87(4)(b)] may cause a shift of adjusted cost base from one class of shares of a predecessor corporation to a different class of shares of the new corporation…. 1.73 However, the CRA will not apply paragraph 87(4)(b) to reallocate the adjusted cost base of the shares of the new corporation if: (a) the amalgamation agreement provides that the preferred and common shares of the predecessor corporation are to be converted into preferred and common shares, respectively, of the new corporation, or (b) for a short-form amalgamation, the issued shares of one of the predecessor corporations become shares of the new corporation under the relevant corporate legislation. … 1.75 In situations where an amalgamation is used to shift all or part of the value of a shareholder's predecessor corporation shares to a person related to the shareholder whose interest in the new corporation will be enhanced by the shift in value, the rollover provided in subsection 87(4) will be denied in respect of that shareholder. ...