Would the capital gains deduction be available to an individual who disposes of all of the shares of "Opco") to another corporation ("Sonco") held by the individual’s adult son, in consideration for a 10-year interest-bearing note payable over 10 years/ CRA stated:
[A]ll the conditions for the application of subsection 84.1(1) would be satisfied … [thereby] result[ing] in a dividend rather than a capital gain … .