2. Borrow instead of sell
Does not transferThis is the one worth being blunt about. Ellison borrows against liquid, exchange-traded, pledgeable stock at bank terms, through five global banks. Shares of a Canadian-controlled private corporation are not collateral a bank will lend against on anything resembling those terms — there is no market price, no ability to liquidate, and the lender ends up underwriting you personally rather than the asset.
And the obvious workaround is specifically blocked. A loan from your own corporation to you as shareholder is caught by section 15(2) and included in your personal income unless repaid within one year of the end of the corporation’s following taxation year. Interest on money borrowed to earn income is deductible under section 20(1)(c), which is a real but much smaller lever, and it is about financing an investment, not about living off your balance sheet.
The honest version: buy-borrow-die needs a liquid public stock. You do not have one, and no amount of structuring manufactures one. Anyone selling you a private-company version of this is selling you a personal guarantee with extra steps.