S. 84.1(2.3)(a)(i), as part of the former (private-member bill) intergenerational business transfer rules, provided that if, otherwise than by reason of death, the children’s purchaser corporation disposed of the subject corporation shares within 60 months of their purchase, the exception in s. 84.1(2)(e) from the application of s. 84.1 was deemed never to have applied.
2022-0953991E5 F indicated that, consequently, if the purchaser corporation amalgamated, within the 60-month period, with the subject corporation, then the resulting disposition pursuant to s. 87(11)(a) by the purchaser of the subject shares would engage the s. 84.1(2.3)(a)(i) exclusion.
CRA now indicated that s. 87(2)(j.6), which provides for continuity on an amalgamation for the purposes of ss. 84.1(2.31) and (2.32), has a relevant scope which is limited to those two provisions and does not deem there to be no disposition on an s. 87(11) amalgamation for purposes of access to the former s. 84.1(2)(e) rule.