11 January 2010 External T.I. 2009-0340591E5 F - Specified class - 256(1.1) of the Act -- summary under Subsection 51(1)

Where a shareholder exchanged all its Class A shares for Class B shares of the same corporation pursuant to what CRA accepted as being a s. 51 exchange, CRA characterized the Class B shares as having been issued, for purposes of the test in s. 256(1.1)(e), for consideration equalling the FMV of the exchanged Class A shares.