Ms. A, the sole shareholder of Zco (A CCPC), sold her shares to her brother (Mr. B, also a resident). Was there an acquisition of control of Zco and, if so, did the balance of Zco's "CDA" and "RDTOH" became nil?
CRA indicated that although Mr. B acquired de jure control of Zco, he was deemed not to have acquired control of Zco for various listed purposes by virtue of s. 256(7)(a)(i)(A), as control of Zco was acquired solely as a result of his acquisition of shares from a related person (his sister). The balance of Zco's "CDA" and "RDTOH" did not become nil by virtue only of control of Zco having been acquired by Mr. B.