Your question is FAR to complex.to answer on this forum. The election under SS 85(1) to transfer property to a Taxable Canadian corporation must be filed and approved by CRA. They will consider the value of the share plus non-share consideration to determine the tax consequences of this transfer. The services of a qualified tax professional are strongly recommended as the tax consequences can be significant for both the transferor and the transferee if not properly handled and reported.. For more info please see http://www.cra-arc.gc.ca/E/pub/tp/it291r3/it291r3-e.html
