I believe the exchange of CMM for WTG shares is a taxable event. CRA has not given me a definitive answer but after discussing the issue with CRA and reading about it the key point in my determination is that WTG is NOT a Canadian corporation. WTG is incorporated in the British Virgin Islands. According to the CRA a share for share exchange, as defined in the Canadian Income Tax Act, states that for a "rollover" (non-taxable event) to occur the acquiring company must be a Canadian company. If you look at the Corporate structure of WTG you will see that CMM is a Canadian company owned by WTG, and that is no doubt where the "Exchangeable" shares sit. If you got WTG shares you got a British Virgin Island's company.

This really sucks for me as I have a Capital Gain. Someone, anyone, please prove me wrong as I'm headed for a large tax bill.

Quote: "In order for the conditions in subsection 85.1(1) to be satisfied, the purchaser must be a Canadian corporation"

http://www.cra-arc.gc.ca/E/pub/tp/it450r/it450r-e.html

http://www.whitetigergold.com/site/corporate/corpStructure.php