Koo - Again, I am not trying to dissuade anyone from doing the transfer, just trying to make sure everyone knows the snags there might be. Probably, everyone or most doing it will win by doing it. The person in the example I gave yesterday did win. He/she probably saved six figures up front on the windfall and lost five figures later through the audit. I am just making aware that can happen so people are not blindsided by it. Also, had he run into a nasty auditor, he might not have done nearly as well with penalties and interest added on. One additional penalty that I didn't mention yesterday was the over-contribution to the TFSA by transferring too many stocks at a too low price so when the CRA price is used, there is a very large over-contribution. Again it would have to be decided whether it is a mistake or an intentional deception to avoid taxes. You just have to be ready to fight this out with them should it arise. This might be a couple of years down the road so make sure you still have access to the funds to clear it up. 

Your idea above would probably get rid of the issue, definitely the deception problem as you would be attempting to use an actual price. Probably most discussing this want to do it at a much lower price than that so they can move more shares. That's understandable! Another thing is that most probably want to do it sooner than later in case of a buy-out pre-IPO. These are all just things you have to weigh in your decision. Just be comfortable with the decision you make.

Another thing to weigh is this a better move or transferring RVX shares into you TFSA which you know the price of. Choose what works better for you! By the hints I often hear on this board, I would guess that many own enough RVX shares that they have not yet been able to move all of them into their TFSA.