CRA states that no intention to claim exemption on future recognition of a capital gains reserve claimed on a s. 84.1 transfer to a purchaser corporation is irrelevant to the operation of the ACB grind

CRA considers that s. 84.1(2.1) essentially treats a resident individual who. having made a non-arm’s length transfer of shares to a purchaser corporation, then claims a capital gains reserve on the disposition, to have claimed a capital gains deduction on the disposition to the extent of the individual’s unused capital gains exemption room in that year, irrespective of whether such exemption was actually claimed and regardless whether there is no intention to claim the deduction when the reserve is recognized in future years.

Neal Armstrong. Summary of 2015-0594461E5 under s. 84.1(2.1).