Respecting a question as to how CRA would view the capital of preferred shares that are redeemed with the proceeds of borrowed money, where the preferred shares were issued under an s. 85(1) rollover transaction and were deemed under s. 85(2.1) to have zero paid-up capital, CRA stated:
"In the situation described, the CRA would examine among other things, the accounting method used for the rollover transactions to determine whether the borrowed funds replenished the capital the borrower previously used for eligible purposes. This is a question of fact which can be resolved only after the facts surrounding a specific situation have been fully analyzed."