11 October 1996 APFF Roundtable, 7M12910 - APFF ROUND TABLE -- summary under Subsection 245(4)

As an example of a transaction where a taxpayer sought to avoid application of s. 84.1, RC referred to a taxpayer who implemented a reorganization under s. 86 with the aim of converting voting shares of the corporation involved in the transfer into non-voting shares to avoid the transferred corporation being related to the purchaser.