Samuel Rosen Establishes a New Corporation, Arranging to Have All

Samuel Rosen establishes a new corporation, arranging to have all of its common shares issued to his adult daughter for cash of $500. Mr. Rosen then transfers, using ITA 85, non-depreciable capital property with an adjusted cost base of $67,500 and an estimated fair market value of $87,750. The transfer is made at an elected value of $67,500. As consideration for this property, the corporation gives Mr. Rosen a note for $67,500 and preferred stock with a fair market value and a legal stated capital of $20,250. A CRA reassessment of this transaction determines that the actual fair market value of the property transferred is $100,000. Mr. Rosen reluctantly accepts this value.
After the reassessment, Mr. Rosen and his daughter sell their shares for their fair market value.
Describe the tax consequences of these transactions for both Mr. Rosen and his daughter. How would these tax consequences differ if Mr. Rosen had simply sold the non-depreciable capital property for its post-reassessment fair market value of $100,000?