I believe this point could be moot. Liard is not publically traded right? ( i don't know but assume not). Has Liard ever made any money or received any royalties? (Again, I don't know, but am assuming NO).
As a result any valuation is subjective at best. Remember the argument about CUU Value is what you have / Get, Price is what you pay. What is Liard really worth right now? No revenues. The value for tax purposes can't really have increased as there are only contracts saying that when / if things happen, then there will be royalties.
Another potential point is that the contracts were negotiated what 8 years ago. If it is only the transfer that we are waiting on then in therory the value was established at the time the contract was signed saying that at BFS then the shares get transferred. They should constitute part of the compensation agreed to when the original contract was signed. That should mean the value was locked at that time, right?
These are just the ramblings of a former CRA auditor. Go ahead and poke holes in my therories and assumptions. If I said something stupid I appologise in advance.
Nut