In finding that the shares of a UK subsidiary were disposed of when the shares were cancelled on completion of voluntary dissolution proceedings CRA stated:
[I]t would be inconsistent with the spirit of the law to consider the disposition of the shares of a controlled foreign affiliate to have occurred as soon as the shareholders become eligible for partial proceeds of disposition on a wind-up because not only is it impossible to compute the full amount of the gain at that time, any FAPI that may be earned by the affiliate subsequent to that time presumably could not be considered to be in respect of shares owned by the taxpayer for the purposes of subsection 91... .