23 September 2004 External T.I. 2004-0088801E5 F - Stop-Loss Provisions -- Grandfathering -- summary under Paragraph 248(5)(b)

Grandfathering regarding the stop-loss rule in s. 112(3.2), which turned on the shares being considered to have been held by an individual continuously from April 26, 1995 onwards, did not apply to preferred shares issued as a stock dividend on common shares held by the individual on and from that date notwithstanding that s. 248(5)(b) deemed the preferred shares to be substituted property.