The issued and outstanding shares of two classes of shares of a QBCA corporation have identical attributes except that the 100 Class A shares and 100 Class B shares have aggregate issued and paid-up capital of $100,000 and $100, respectively. Are they identical for s. 47 purposes? CRA responded:
[T]he issued and paid-up share capital attributable to a class of issued and outstanding shares of the capital stock of a corporation is an attribute of that class. …
In the example submitted, the CRA would not consider a Class A share … to be identical to a Class B share … . Indeed, the issued and paid-up share capital of a Class A share of the capital stock of the particular corporation would be $1,000, while the issued and paid-up share capital of a Class B share of the capital stock of the particular corporation would be $1.