Terminal Norco Inc. v. The Queen, 2006 DTC 2897, 2006 TCC 139 -- summary under Ownership

In order to avoid Quebec mutation tax, the taxpayer transferred the assets of a business division to a newly-incorporated wholly owned subsidiary and then sold the shares of the subsidiary to a purchaser. The taxpayer was unsuccessful in arguing that these transactions should be viewed as an indivisible transaction or as two transactions that occurred simultaneously. Accordingly, the taxpayer was found to have controlled the subsidiary "immediately after" the transfer.