After noting that safe income of Opco “old” common shares was required to be allocated, on their s. 51 exchange for new common shares and preferred shares, based on the new shares’ respective FMVs, CRA stated:
The Compliance Programs Branch is now accepting requests from taxpayers regarding complex valuation matters. These requests can be made to the CRA where a taxpayer plans to complete one or more specific transactions or, when transactions are completed, before filing an income tax return.
The purpose of the service is to assist taxpayers by answering their questions about the methods or approaches used. However, this Directorate does not provide an opinion on the value of a property or on estimates or statements that a taxpayer proposes. The CRA also does not discuss specific elements involved in determining the FMV of a particular property.