In 2014-0552711E5 “Application of paragraph 251(5)(b)” dated September 16, 2015, the CRA was asked whether a non-binding letter of intent could engage paragraph 251(5)(b) of the ITA. The CRA commented that if the letter of intent constitutes a contract “in equity or otherwise”, then it would engage paragraph 251(5)(b) if its subject matter involves a right to acquire shares or voting rights.