13 January 2012 Internal T.I. 2011-0428371I7 - Paragraph 110.6(14)(b) -- summary under Paragraph 110.6(14)(b)

certain share put/cal rights contained in a unanimous shareholders agreement would not be considered to be rights "under" a purchase and sale agreement, given that (contrary to the situation in the Chartier decision) such put/call rights were not referred to in the purchase and sale agreement.