7 October 2011 APFF Roundtable Q. 17, 2011-0412171C6 F - 112(7) - Share-for-Share Exchange - 85(1) -- summary under Disposition

Where there is an exchange of 100 common shares in the capital of a corporation for 100 "new" common shares in its capital, there would "not necessarily" be a disposition of the old common shares (given that the share rights are identical), so that the s. 85(1) election is unavailable.