The only issue as I see it would concern the TFSA contribution limits when the transfer is done to ensure maintaining the allowed limits. Let's say at a unit fair value of $1.00, you would be allowed to transfer 5500 for the year of transfer, assuming you don't have additional contribution room from previous years. The problem surfaces should Zenith issue an IPO that would be much greater than the fair value because CRA will surely use the IPO as the fair market value for all Zenith shares, in the event of an audit.

This dilemma should be expressed vigorously to Sarah, so perhaps the new posting will show a "fair market value" as opposed to "fair value," unless of course, an IPO is in the immediate horizon, which I highly doubt. :o) 

IMO....Koo