In Advance Tax Ruling 2011-0418571R3 (recently released), the CRA ruled that an amendment to an existing plan established pursuant to Regulation 6801(d) (DSU plan), which amendment permitted the value of a participant’s DSUs to be paid in common shares of the company, did not result in a disposition of the participant’s rights under the DSU plan. The purpose of the amendment was to remove an unwarranted volatility in the earnings reported by the company each fiscal quarter and, as well, to provide the company with additional flexibility in its use of cash.