I skip over the tax discussion in the article because it's US.  i don't know how it's handled in Canada.  The concern for me with a CVR is that shareholders bear all the risk and the acquiring company has every incentive to drag out payments or never pay them at all (eg. "...If the milestone is never reached, or is reached, but too late, the acquirer pays nothing...").  I'd rather have a straight cash deal for less money and get it all up front. 

I'm also less than impressed with what growacet reported (May 3rd) DM saying about some money from a Zenith deal going into RVX.  If that happens it had better be a sweet deal for Zen shareholders and a tough deal for RVX.