This is the one that scales down, and it is the only one today that does. Nothing in it requires a billion dollars, a public stock or a foreign domicile — it requires only that the structure exist before there is a transaction to run through it, which is exactly the property Smart Bloks (2021, sold 2026) and Control Empresarial demonstrate.

The Ontario shapes that do the same work:

• Holdco above Opco. Lets surplus cash leave the operating company as an intercorporate dividend between connected corporations, generally on a tax-deferred basis, and puts it behind a creditor wall rather than inside the business that carries the risk.
• Discretionary family trust holding the growth shares. The vehicle that makes it possible for more than one person to claim the lifetime capital gains exemption on a later sale of qualified small business corporation shares. The exemption amount is indexed and has changed in recent years — confirm the current figure rather than working from one you remember.
• Estate freeze under section 85. Exchange your common shares for fixed-value preferred shares and issue new growth common to the trust, so future appreciation accrues outside your terminal return.

The timing constraint is the whole point and it is unforgiving: QSBC status depends on asset tests measured over the preceding 24 months, so a company that has accumulated investments or surplus cash cannot be made eligible on the eve of a sale. The structure has to be in place long before the event, which is the lesson the filings actually teach.