28 November 2010 CTF Roundtable, 2013-0487431C6 - Value of Vote-Only Shares – 2010 CTF Conference -- summary under Paragraph 104(4)(a)

CRA generally will ignore any premium that could be attributed to controlling non-participating preference shares, for purposes of subsection 70(5) of the Income Tax Act (the "Act"), where the shares were held to protect the deceased's economic interest in the corporation.

We are not aware of the issue of the valuation of such shares having arisen in any CRA compliance audits involving paragraph 104(4)(a) of the Act. Accordingly, we have not had the opportunity to give full consideration to whether the above position should apply for purposes of that provision.