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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Q1: Both ITA 87, Amalgamations, and ITA 88(1),
Q2: When new shares are issued in an
Q3: Describe, in general terms, the type of
Q5: ITA 86(2)has special rules that must be
Q6: Subsections 88(1)and 88(2)cover two different types of
Q7: When new shares are issued in an
Q8: Briefly describe the general rules applicable to
Q9: When preferred shares are issued in an
Q10: Briefly describe the calculation of the PUC
Q11: List two conditions that are necessary for
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