Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. Monsieur (her husband) then subscribed for Class A shares. After finding that s. 85(1)(e.2) likely was applicable unless a price-adjustment clause was applied, the Directorate indicated to the TSO:
… [If] you decide to recognize the price adjustment clause … the taxpayer must file an amended election to give effect to the price adjustment clause.