Under s. 49 of the new Québec Business Corporations Act, it is possible to create classes and series of shares with exactly the same rights and restrictions. Those classes or series have their own issued and paid-up share capital accounts by virtue of the QBCA. Would two identical classes of shares created under the QBCA have their own paid-up capital for tax purposes? CRA responded:
To the extent that shares with exactly the same rights and restrictions belong to two distinct classes under corporate law, the paid-up capital of each of those classes will be calculated separately.