CAinPlap, I posted the article but it was promptly deleted and shortly thereafter I received a warning from Agoracom indicating I had violated one of the 6 rules by making the post.  I inquired requesting an explanation but haven't heard back.  Perhaps someone thought I was giving advice, not sure why as the only advice given was to get the advice of a professional...

At any rate, here is the link to the article which refers to CRA Income Tax Act s. 40(2)(g)(iv)(A) and (B):

http://www.taxtips.ca/personaltax/investing/transfersharestorrsp.htm

Guernsey