It is common for corporations to include multiple share classes in their corporate structure in contemplation of subsequent reorganizations or restructurings. Is the filing of articles of amendment required in order to meet the condition in s. 86(1) that there has been a reorganization of capital?
CRA indicated that it is maintaining its longstanding position that a reorganization of capital in the s. 86(1) context should normally require an amendment to the articles of incorporation. As noted in 2010-0373271C6, if s. 86(1) is not applicable in a given situation, there could be another rollover provision such as s. 51 or 85 that could apply.