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Can you exchange shares of a Canadian corporation for a US corporation on a tax free basis?

Can you exchange shares of a Canadian corporation for a US corporation on a tax free basis?

If there is no Capital gain involved (if the cost of the US shares is the same as the cost for the Canadian shares).

Private Canadian corporations have some rollover rules that can apply, but not when you are rolling over to a non-canadian controlled corporation (so it wouldn't apply in the situation you describe).

International taxation and corporate reorganizations are both complex areas and you might be best served by having an accountant and possibly a lawyer involved before you do anything.

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