Two individuals transferred the shares they held of a particular company to their respective holding companies which, in turn, each disposed of a portion of those shares to the individuals’ respective spouses in consideration for non-interest-bearing notes. Following an exchange of such shares for shares of another class, and an amalgamation of the company, the spouses disposed of the shares of Amalco at a gain. In finding that s. 74.2(1) applied, the Directorate stated:
[W]e consider it possible that an indirect transfer of the individuals' shares to their spouse was effected through their respective holding companies … [so] that the shares disposed of by the spouses … constitute substituted property for the property transferred indirectly by the individuals,