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SHARE EXCHANGES - Canadian Bar Association

Felesky Flynn LLP1 TAX LAW FOR LAWYERSSHARE EXCHANGESF elesky Flynn LLPH2O 9292342 Section 51>Section 51 provides a tax-free rollover for certain conversions of debt issued by a corporation into shares of that corporation and conversions of shares of a corporation into other shares of that same corporation.>Section 51 does not apply to a conversion if section 85 or 86 applies: 51(4).Felesky Flynn LLPH2O 9292343 Basic Rules Paragraphs 51(1)(a) and (b)>The investor must give up shares or debt of the issuer corporation in exchange for shares of the issuer.

Felesky Flynn LLP H2O 929234 3 Basic Rules –Paragraphs 51(1)(a) and (b) > The investor must give up shares or debt of the issuer corporation in exchange for shares of the issuer.

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