8 October 2010 Roundtable, 2010-0373231C6 F - Application of subsections 51(1) and 85(1) -- summary under Subsection 51(1)

CRA's position in IT-291R3, that an election under s. 85(1) potentially is available even if the shares to be issued are not yet part of the transferee's authorized capital, is inapplicable to s. 51(1) because the wording of s. 51(1) is clear as to the simultaneous nature of the exchange.