In connection with indicating that, where an individual shortly after commencing a proprietorship, transfers all of the assets used such active business to a newly-incorporated corporation in exchange for treasury shares of the corporation, the individual can benefit from the s. 110.6(2.1) deduction even if the individual disposes of those shares within 24-months of having commenced the proprietorship, CRA stated:
[T[here is no mechanism in [the s. 110.6(14)(f)(ii)] relief rule that combines the period during which the business was operated as a sole proprietor with the period during which the shares of the corporation were held to ensure that this period is at least 24 months. Such a mechanism exists, for example, in the case of relief for shares issued as consideration for other shares or as consideration for the payment of a stock dividend. (See paragraph (e) of the definition of QSBCS.)