You have painted a somewhat bleak picture of the tax situation. As a generalisation, it is quite possible in the Canadian tax world to separate Windfall, or other properties , to NOT shareholders at little or no tax cost, since the value of the core holding is virtually all of the current value. The tax at this point per share would be pennies. Were NOT to IPO it instead and keep a chunk of the $ , NOT has lots of tax cover for any gainrealized.