CRA recently released a letter which discusses whether the transfer of 100% of the voting common shares of a taxable Canadian corporation to a public foundation will result in the public foundation acquiring control of the corporation under paragraph 149.1(3)(c) of the Income Tax Act. CRA ruled that the foundation was not deemed to have acquired control of the corporation because it did not acquire for consideration more than 5% of the common shares of the corporation.

CRA letter on donation of shares to public foundation