The problem isn't that it is hard to come up with a value rather is it a value that CRA will accept in an audit. Literature on the subject says there are numerous ways to value a company not listed but has Zenith done it in a way that CRA will accept. They might not have as they warn you to only use it for one purpose. Zenith is one of the harder ones to value due to the stage of the company with no revenues and so many intangibles. Most of the usual metrics do not exist. In an audit, they might demand different metrics for Zenith to use in the calcualtion than what was used in their current valuation.

Do you know some non-listed Canadian corporations that have had in-kind transfers done? Most of the ones you are referring to would probably be private corporations and do not qualify for registered accounts. Zenith is an unlisted public company so does qualify. It is just the transfer-in price that becomes an issue. So far, I have only heard of TD willing to do these and I don't even know if they have any liability if they should not have. Probably not. Just thoughts!