Because most transactions contemplated in s. 85.1 (unlike those contemplated in s. 85) significantly change the taxpayer's participation in capital, the transitional provisions will not be expanded to cover s. 85.1.
Furthermore, a "disposition made in accordance with a will, accompanied by-laws or the terms and conditions of a share redeemable by mutual agreement or at the pleasure of the holder, is not considered made in accordance with an agreement in writing."