S. 84.1(2.3)(c) provides that the taxpayer must provide the Minister with an independent assessment of the FMV of the subject shares and an affidavit signed by the taxpayer and a third party attesting to the disposal of the shares. What are the implications to the taxpayer if the required information is not provided or is deficient?
After noting that it has provided guidance regarding the documentary evidence required by s. 84.1(2.3)(c) at: Affidavits and valuations for the transfer of a small business, family farm or fishing corporation (Bill C-208), CRA stated:
[T]he documentary requirements are integral to the application of paragraph 84.1(2)(e) of the Act. That is, these requirements must be met for paragraph 84.1(2)(e) to apply.