The least they can do is to show a "fair market value" based on the last PP of $2/unit. In my opinion, this would satisfy both the brokerage houses and CRA.

A $2/unit transfer to a TFSA account represents one's position in truer light with respect to a potential CRA audit down the road. That may limit the amount of Zenith share units one can transfer to a TFSA, but at least one would safeguard some, tax-free capital gains should Zenith shares get to trade on TSX or Nasdaq down the road.

I note that the maximum amount of contribution from 2009, the inception of TFSA  is $63,500.00.

IMO....Koo