19 June 2000 Internal T.I. 2000-0027787 - OPTIONS, ROLLOVER -- summary under Subsection 85.1(5)

Where a U.S. public company of which the taxpayer's employer was a Canadian subsidiary merges with another corporation, s. 85.1(5) will not provide rollover treatment in respect of the issuance of shares by the merged corporations to the taxpayer in exchange for his employee stock option rights.