Qualified small business corporation shares are disposed of by the taxpayer to a child for FMV proceeds during the taxpayer’s lifetime or on death for deemed FMV proceeds. After noting that the non-arm’s length nature of these transactions did not preclude access to the s. 110.6(2.1) deduction, CRA stated:
… [I]n both of these situations, subparagraph 84.1(2)(a.1)(ii) could apply for the purposes of section 84.1 to reduce the adjusted cost base of the shares acquired by your child.