CRA referred to the finding in Ryall v. Du Bois that in substance a share represented "a portion of the capital" of a company and further stated that:
A share has been defined as any of the equal interest or rights into which the entire capital stock of a corporation is divided.
A Liechtenstein anstalt did not issue shares within the meaning of s. 248(1), as there was only one beneficiary. However, a division of the capital of the anstalt into shares was unnecessary so that it was reasonable to consider that the Canadian resident beneficiary's interest was the equivalent of a share. "For Canadian tax purposes, it should suffice that the interest is what accords him the same rights as are normally conveyed by a share."