The reasoning survives the border even though the vehicle does not. Goldfarb is fixing a transfer value while the price is in the bottom third of its year. The Canadian analogue is an estate freeze: exchange your common shares in the operating company for fixed-value preferred shares and issue new common to a family trust, so future growth accrues outside your own hands at a value you set today.

The timing logic is identical and it points the same way: you want to freeze low. For a private Ontario company that means a defensible valuation at the moment of the freeze — which, unhelpfully, is easiest to defend when the business has just had a bad year, and hardest to justify emotionally for exactly the same reason.