My guess is that in Canada there is a deemed disposition at the time of the swap, hence a tax liability, and that the share valuation of the the acquiring company becomes the new ACB (adjusted cost base) of the acquiring company shares going forward.  I suspect Canada likes to get its cut up front, which means you would need sufficient cash to pay the bill in the year of the sale.  But, it’s possible that the swap allows for a deferred tax liability that doesn’t come into play until the acquired company shares are sold.  Yeah, I’m not sure but it would be good to know.  Sorry for boring our US compadres with such mundane matters.  All speculation anyway.