5 · Threshold-driven rather than price-driven selling (Schuurman)
Partially transfersIf the tax reading of the Elastic sales is right, the general lesson is the useful part: large disposals are often triggered by an ownership percentage or a date, not by a price. Canadian structures have the same kind of hard edges, and they are the ones worth knowing in advance rather than discovering:
- The QSBC active-asset tests above, which are measured at a moment and over 24 months.
- The 21-year deemed disposition for most family trusts — a date certain, set when the trust was created.
- The associated-corporation rules, which make a group share a single small business deduction.
FIRST STEP THIS WEEK · Establish whether any date-certain threshold applies to your current structure inside the next 24 months, and write the dates down. If a family trust exists, its 21-year date is the single most important number in the structure.