200 Class A shares of Opco held by a shareholder had a safe income on hand ("SIOH") and FMV of $200 and $1,000 per share, respectively, and 100 Class F shares with a SIOH per share equalling their FMV of $1,000. The 200 Class A share are converted under s. 51 into 200 Class F shares.
CRA noted:
[W]here there is a transfer of shares on a rollover basis, as provided for in sections 51, 85, 85.1, 86 and 87, the shares issued during the rollover participate proportionally in the SIOH attributable to the shares exchanged immediately before the transfer
CRA went on to indicate that all the Class F shares following the conversion including the newly issued ones will share proportionately is the SIOH formerly attributed to the exchanged shares, so that their average SIOH per share of the Class F shares is reduced from $1,000 to $600.