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Jerome Barris Is 85 Years Old And, While His Spouse

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Jerome Barris is 85 years old and, while his spouse is deceased, he has three children, ages 45, 50, and 52. He owns all of the outstanding common shares of Barris Ltd., a Canadian controlled private corporation. These shares have a PUC and adjusted cost base of $50,000, and a current fair market value of $3 million. He would like to retain operating control of Barris Ltd. However, given his advanced age, he would like to transfer any future growth in the value of the Company to his three children. Briefly explain how ITA 86, Exchange Of Shares In A Reorganization, could be used to accomplish the results desired by Mr. Barris.

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Under ITA 86, Mr. Barris could exchange ...

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