93 CR - Q. 6 (No. 932844)
Where a deferred income plan enters into an agreement to purchase a share in the future at a price that equals the fair market value of the share at the time the agreement is made, tax under s. 206.1 will be exigible for each month during which the agreement is in effect because it is possible that the purchase price will not be equal to the fair market value of the share.
30 July 1990 Decision Summary (Tax Window, Prelim. No. 1, p. 9, ¶1000)
The holder of an exchangeable debenture who exercise the right of exchange will be considered to have acquired the underlying shares for consideration equal to their fair market value.