An accounting colleague has reported to me on a CRA audit involving a price adjustment clause. The CRA challenged the valuation used for a transfer of property. The taxpayer and the CRA eventually agreed on a valuation that was about 80% higher than the value originally used. Nevertheless, the CRA agreed the price adjustment clause was effective. The provisions for the shares issued as consideration used a formula to determine their redemption amount, and so no articles of amendment were needed for the adjustment. Instead, the taxpayer provided the CRA with a copy of resolutions of the corporate issuer increasing the redemption amount of the shares.
